ML20079R203

Response to Second Set of General Interrogatories & Interrogatories on Contentions 29 & 37B

ML20079R203
Person / Time
Site:	Harris
Issue date:	06/17/1983
From:	Bauser D CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Eddleman W EDDLEMAN, W.
Shared Package
ML20079R205	List: ML20079R203 ML20079R208
References
ISSUANCES-OL, NUDOCS 8306220108
Download: ML20079R203 (119)

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UNITED STATES'OF, -

NUCLEAR REGULATORY"C ISSION EEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY ) ,

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

APPLICANTS' RESPONSES TO WELLS EDDLEMAN'S GENERAL INTERROGATORIES AND INTERROGATORIES ON CONTENTIONS 29 AND 37B TO APPLICANTS CAROLINA POWER & LIGHT COMPANY, et al.

(SECOND SET) r l Applicants Carolina Power & Light Company ("CP&L") and North Carolina Eastern Municipal Power Agency, pursuant to 10 C.F.R. 5 2.740b, hereby submit the following responses to

" Wells Eddleman's General Interrogatories on Contentions 29 and 37B to Applicants Carolina Power & Light Company, et al.

(Second Set)." Applicants' provision of answers to Intervenor l

Eddleman's' interrogatories should not be deemed an admission of a

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relevancy with regard to the information provided by Applicants or that sought by Intervenor.

RESPONSES TO GENERAL INTERROGATORIES INTERROGATORY NO. G-1(a). Which contentions of Wells Eddleman do Applicants agree are now admitted in this pro-ceeding, NRC Dockets 50-400/401 0.L.?

, ANSWER. See Applicants' answer filed on April 28, 1983.

INTERROGATORY NO. G-1(b). For each such contention, provide for any answers to interrogatories by Wells Eddleman which Applicants have previously or presently received (except '

those suspended by Board order, if any), the following informa-tion.

ANSWER. The answers to General Interrogatories herein are restricted to Eddleman Contentions 29 and 37B.

INTERROGATORY NO. G-1(c). Please state the name, present or last known address, and present or last known employer of each person whom Applicants believe or know (1) has first-hand knowledge of the facts alleged in each such answer; or (2) upon whom Applicants relied (other than their attorneys) in making such answer.

ANSWER. The following list identifies those persons who provided information upon which Applicants relied in answering the interrogatories on Eddleman Contentions Nos. 29 and 37B and indicates the particular interrogatory answer (s) for which each such person provided information.

m PERSON INTERROGATORY NO(S).

William Webster 29-1(h)&(o) 37B-1(a)&(b)

Ronald Shearin 29-1(a)(v)-(x), (b), (c),

(g), (j), (k), (m) 29-2(j), (k), (1)

Henry Till 29-1(q), 29-2(k) 29-3(1), 29-7(a)-(g)

Richard Yates 29-3(o)(v)-(x)

Helm Lipa 29-3(j)&(k)

David McCarthy 29-1(a)(i)-(iv), 29-1(e), (t)

, Brian McFeaters 29-2(a)-(h)

Michael McDowell 29-3(p)(i)-(iv) ,

George Marquardt 29-1(h) .

John Eads 29-1(f),29-4(a)-(d)

The above individuals are employees of Carolina Power & Light Company, P.O. Box 1551, Raleigh, North Carolina 27602.

PERSOli INTERROGATORY NO(S).

i l John Garibaldi 29-1(b), (g), (n) l 29-3(n) l 29-6(a)-(f) 29-8(a)-(c)

Guy Martin, Jr. 29-1(p), (r) 29-3(a)-(h), (m),

(o)(i)-(iv), (p)(v)-(viii) 29-4(e)-(n) 29-5 l

Waclaw Bielawski 29-1(s), 29-6(f)

Gersh Rimer 29-1(s), 29-6(f)

The above individuals are employees of Ebasco Services, Inc.,

Two World Trade Center, New York, New York 10048.

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m PERSON INTERROGATORY NO(S).

Dr. G. Hoyt Whipple 37B-3(a)-(e), (f), (j) 37B-4(a)-(e)

The above individual is an independent consultant to Carolina Power & Light Company, 3301 Rutland Loop, Tallahassee, Florida 32312.

INTERROGATORY NO. G-1(d). Please identify all facts concerning which each such person identified in response to G-1(c)(1) above has first-hand knowledge.

ANSWER. See answer to Interrogatory No. G-1(c).

INTERROGATORY NO. G-1(e). Please identify all facts and/or documents upon which each person identified in response to G-1(c)(2) above relied in providing information to respond to the interrogatory, including the parts of such documents relied upon.

ANSWER. All facts or documents relied upon by those individuals identified in the answer to Interrogatory No.

G-1(c) are indicated within each response to the specific interrogatories on Contentions 29 and 37B.

1 INTERROGATORY NO. G-1(f). Please identify any other document (s) used or relied upon by Applicants in responding to the interrogatory.

ANSWER. See answer to Interrogatory No. G-1(e).

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g INTERROGATORY No. G-1(g). Please state which specific fact each document, identified in G-1(a) and G-1(f) above, supports, in the opinion or belief of Applicants or which Applicants allege such document supports.

ANSWER. Within each response to the specific interroga-tories on Contentions 29 and 37B, Applicants have indicated a

which specific facts are supported by the documents identified.

INTERROGATORY NO. G-1(h). Please state specifically what information each person identified in response to G-1(c)(1) or G-1(c)(2) above provided to or for Applicants' affiant in j answering the interrogatory. If any of this information is not l documented, please identify it as " undocumented" in responding to this section of General Interrogatory G-1.

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I ANSWER. See answer to Interrogatory No. G-1(c).

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i l INTERROGATORY NO. G-2(a). Please state the name, present or last known address, title (if any), and present or last t known employer, and economic interest (shareholder,: bondholder, l

contractor, employee, etc.) if any (beyond expert or other witness fees) such person holds in Applicants or any of them, for each person-you intend or expect to call as an expert i witness or a witness in this proceeding, if such information l

has not previously been supplied, or has changed since such information was last supplied, to Wells Eddleman. This applies to Eddleman and Joint Contentions as admitted, or stipulated by Applicants.

l ANSWER. Applicants have not yet identified the expert (s) or other witness (es) they expect to call in this proceeding.

When witnesses are identified, Applicants will supplement this -

response in a timely manner.

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4 INTERROGATORY NO. G-2(b). Please identify each contention regarding which each such person is expected to testify.

ANSWER. See answer to Interrogatory No. G-2(a).

INTERROGATORY NO. G-2(c). Please state when you first contacted each such person with regard to the possibility of such person's testifying for Applicants, if you have contacted such person.

ANSWER. See answer to Interrogatory No. G-2(a).

INTERROGATORY NO. G-2(d). Please state the subject matter, separately for each contention as to which each such person is expect ed to testify, which each such person is expected to testify to.

ANSWER. See answer to Interrogatory No. G-2(a).

INTERROGATORY NO. G-2(e). Please identify all documents or parts thereof upon which each such witness is expected to, plans to, or will rely, in testifying or in preparing testi-mony.

ANSWER. See answer to Interrogatory No. G-2(a).

INTERROGATORY NO. G-3(a). Please identify any other source (s) of information which Applicants have used to respond to any interrogatory identified under G-1 above, stating for each such source the interrogatory to which it relates, and what information it provides, and identifying where in such source that information is to be found.

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ANSWER. Applicants have identified all such other sources of information, if any, within the answers to the specific interrogatories set forth herein.

I INTERROGATORY NO. G-3(b). Please identify any other source (s) of information not previously identified upon which any witness identified under G-2 above, or other witness, has used in preparing testimony or exhibits, or expects to use in testimony or exhibits, identifying for each such source the witness who is expected to use it, and the part or part(s) of such source (if applicable) which are expected to be~used, and, if not previously stated, the fact (s) or subject matter (or both) to which such source relates.

ANSWER. See answer to Interrogatory No. G-2(a).

INTERROGATORY NO. G-4(a). Please identify all documents, and which pages or sections thereof Applicants intend or expect to use in. cross-examination of any witness I call in this hearing. For each such witness, please provide on a timely basis (ASAP near or during hearings) a list of all such documents, the subject matter Applicants believe they relate to, and make the document (s) available for inspection and copying as soon as possible after Applicants decide or form intent to use such document in cross-examination.

l ANSWER. Applicants have not yet identified which docu-l ments, if any, they intend to use in cross-examination of Mr.

Eddleman's witness (es).

INTERROGATORY NO. G-4(b). Please identify any undocumen-ted information Applicants intend to use in cross-examination of each such witness for me.

ANSWER. See answer to Interrogatory No. G-4(a).

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!. o INTERROGATORY NO. G-5(a). For each contention Applicants state or admit is an admitted Eddleman contention under G-1(a) above, or an admitted joint intervanor contention, please state

~whether Applicants have available to them experts and informa-tion, on the subject matter of the contention.

ANSWER. Applicants have available to them experts and information on the subject matter of Contentions 29 and 37B.

INTERROGATORY NO. G-5(b). If the answer to (a) above is other than affirmative, state whether Applicants expect to be i able to obtain expertise in the subject matter, and information on it, and if not, why not.

I ANSWER. Not applicable.

INTERROGATORY.NO. G-7(a). Please identify all documents )

which Applicants plan, expect or intend to offer as exhibits (other than for cross-examination) with respect to each Eddleman contention admitted in this proceeding which (i) is included in your current response to G-1(a), or (ii) is the subject of interrogatories in this set; please state for which contention or contentions each exhibit will be or is expected to be offered.

ANSWER. Applicants have not yet identified those docu-ments they intend to offer as exhibits relating to Eddleman l Contentions 29 and 37B.

l INTERROGATORY NO. G-7(b). Please identify all documents which Applicants plan, expect or intend to use in cross-examination of any other parties' witnesses or joint intervenor witness in this proceeding, with respect to (1) Eddleman contentions identified under G-7(a)(1) (or G-1-(a)) above, or any other Eddleman contention which is the subject of inter-rogatories in this set; (ii) each Joint contention now admitted in this proceeding; (iii) per our agreement of 4-8-83, each contention of each other party to this proceeding which is currently admitted. Please identify for each such document the witnesses,'or witness, and all contentions with respect to whom (or which) that document is planned, expected, or intended to be offered or used.

ANSWER. Applicants have not yet identified those docu-ments they intend to use for cross-examination of any wit-nesses.

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l INTERROGATORY NO. G-7(c). Please identify which of the documents identified in response to (b) above (1) will be offered into evidence by Applicants, and (ii) which of the same documents Applicants expect to offer into evidence or intend to offer as evidence or exhibits in this proceeding.

l l ANSWER. See answer to Interrogatory No. G-7(b).

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INTERROGATORY NO. G-8(a). Please identify, for each Eddleman contention which is the subject of this or an earlier set of interrogatories, all information not previously

' identified.which was (1) used or relied on in preparation of l

Applicants' responses to that contention and all contentions superseded by it-(per transcript of July 1982 special prehear-ing-conference, the Board's September 1982 order admitting l contentions, or stipulation by Applicants or W.E.), with I respect to any facts alleged therein, identifying for each such fact the specific source (s) of information used or relied upon.

i l INTERROGATORY NO. G-8(b). Please identify all persons who supplied information relied on or used in Applicants' response to each contention for which information is requested in G-8(a) above. (ii) Please identify for each such person what informa-r tion was supplied, and with respect to which contention (s) each l item of information supplied was used. (iii) Please state all l known qualifications of each such person with respect to the subject matter of the contention for which that person supplied information. -

INTERROGATORY NO. G-9(a). Please identify all information l not identified in response to the above general interroga-tories, including all documents, which Applicants rely on or intend to use-in making their case or carrying their burden of proof in this proceeding, with respect (i) to each Eddleman 1 contention which is the subject of this or an earlier set of l

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Eddleman interrogatories to Applicants; (ii) with respect to each joint contention on which discovery is now open under the Board's March 10, 1983 order, or on which discovery has been open under said order establishing a discovery schedule. (The phrase "or on which discovery has been open" is intended to keep this interrogatory current and continuing for information and documents which Applicants rely on or form intent to use after the formal close of discovery. I interpret Applicants' continuing interrogatories to apply continuously from their date of submission to me, and I intend these to apply likewise.) -

OBJECTION. Applicants object to Intervenor Eddleman's Interrogatories Nos. G-8 and G-9. Interrogatories Nos. G-8 and G-9 as demonstrated below, are repetitious, overly broad, are an undisguised attempt to compel Applicants to prepare Intervenor's own case, and attempt to circumvent the restric-tions of 10 C.F.R. 5 2.740(b)(2) against routine discovery of l

L materials prepared by Applicants in anticipation of the l

hearing.

Mr. Eddleman has elsewhere requested "all facts" known to persons with first-hand knowledge or relied on by such persons l

in providing information for answers to any of his interroga-tories (Interrogatory No. G-1(d)); all facts and/or documents used by such persons in answering his interrogatories (Interrogatory No. G-1(e) and (f)); the identification of all documents used by witnesses or potential witnesses

.(Interrogatory No. G-2(e)); all potential exhibits (Interrogatory No. G-7(a)); all potential documentary evidence (Interrogatory No. G-7(c)); all documents or information which

are-potentially useful for cross-examination of Mr. Eddleman's 1

o or any other party's witnesses (Interrogatories Nos. G-4(a) and (b) and G-7(b)); and "any other source (s) of information which Applicants have used to respond to any interrogatory" admitted in these proceedings. Interrogatory No. G-3(a). Although the sum total of the interrogatories referred to above logically encompasses all the relevant and useful information available, Mr. Eddleman now seeks "all information not previously identified" which was used or relied on in any degree in preparation of Applicants' responses and the identity of all persons who supplied any information for those responses.

Interrogatory No. G-8(a) and (b). In addition, Mr. Eddleman ,

also demands "all information not identified" on which Applicants intend to rely in " making their case or carrying their burden of proof in this proceeding" concerning Intervenor's or any joint contentions. Interrogatory No.

G-9(a). It can be fairly stated that Mr. Eddleman wants the totality of information, documents and personal identities, no matter how tangentially related to the contentions admitted in this proceeding, of which Applicants have possession, access or knowledge. In his attempt to leave "no stone unturned" Mr.

Eddleman has gone too far. Intervenor's General Interrogatories No. 8 and 9 do not seek to narrow the issue or selectively elicit useful and relevant information but rather are classic examples of the type of " catch-all" interrogatories that are justly rejected by the Commission and Federal judicial authorities as an abuse of the administrative process.

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Interrogatory No. G-9 clearly attempts to shift the burden of Mr. Eddleman's case preparation to Applicants. In fact, the interrogatory asks as much: " identify all information ...

which Applicants rely on or intend to use in making their case j or carrying their burden of proof...." "There'is nothing in the Federal Rules of. Civil Procedure that compels either party to present its case in advance of trial." United States v.

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Grinnell Corporation, 30 F.R.D. 358, 362 (D.R.I. 1962). Use of discovery as a tool to substitute for a party's own investiga-tion, necessary to present his case, or to force an early and premature presentation of an opponent's case has been condemned ,

as an abuse of discovery. UINTA Oil Refining Company v.

Continental Oil Company, 226 F. Supp. 495, 501-505 (D. Utah 1964); Fishman v. A.H. Riise Gift Shop, Inc., 68 F.R.D. 704 l (D.V.I. 1975); Central Hide & Rendering Co. v. B-M-K l

( Corporation, 19 F.R.D. 294 (D. Del. 1956). These accepted principles of federal judicial practice have been adopted by i

Atomic Safety and Licensing Boards in NRC proceedings. See Duke Power Company, et al. (Catawba Nuclear Station, Units 1 and 2), ASLBP 81-463-010L, Memorandum and Order (Rulings on l Motion to Compel) (April 18, 1983) (slip op. at 3) (attempt to 1

shift burden of case preparation to Applicants is impermissible).

Read literally, Interrogatories Nos. G-8 and G-9 would also require the disclosure of protected and privileged -

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material'. To the extent that the interrogatories ask for trial preparation materials, Applicants also raise the objection that such materials are protected. See 10 C.F.R. 5 2.740(b)(2).

RESPONSES TO INTERROGATORIES ON CONTENTION 29 l INTERROGATORY NO. 29-1(a). N.B., as used below, " monitor"

! includes the meanings " detector" and " detection device".

Please identify all radioiodine monitors at Harris which will continuously sample levels of any radioactive isotope of iodine, or any combination of such isotopes, which is located (1) on the upstream side of any filter or device which is designed, or claimed by Applicants, to remove radioiodines from a gas or air stream at the Harris plant; (ii) directly on the downstream side of any such filter or device per (i) above; (iii) on the downstream side of any such filter or device per ~

(1) above before such stream of gas or air (including any contaminants and radioactive materials) merges or mixes with  ;

any other vent, duct, room, space or other stream or source of air or gas which originates within the Harris plant contain-

ment, spent fuel building, auxiliary building, or other areas i into which the FSAR or ER contemplates or states that radicio-dines can be present.during normal operation (including by leaks or accidental transport which does not cause the plant to cease operation); (iv) at any other point downstream of any such filter or device per (i) above but before the release of the air or gas stream (including any contaminants or radioac-

! tive material it may include) to the environment; (v) located I

outside any enclosure or building or vent at Harris but within 10 meters of any designated release point for radioiodines per the FSAR or ER as currently revised (vi) located more than 10m but less than 100m from any designated release point per (v) above; (vii) located more than 100 meters from any designated l release point per (v) above; (viii) located between two or more such designated release point per (v) above or within 100 meters of more than one release point, giving for each such .

j continuously sampling monitor its distance from each release i point it is within 100 meters of; (ix) located outside the H- . exclusion area for Harris; (x) located at the boundary of the Harris exclusion area.

ANSWER.

(i)-(iv). Applicants do not possess this information in this form. However, the information can be extracted from the FSAR, Section 12.3.4 and Table 12.3.4-1, Section 11.5.2 and Table 11.5.2-1, and the sections of the FSAR referred to in the

-- above tables..

(v), (vi). No monitors exist in these locations.

(vii). The following air samplers are sited more than 100 meters from any designated release points and are located beyond the exclusion area-at SHNPP.

( a )' Number Direction from SHNPP Distance (0* is true north) 1 25* 3 miles 2 295* 13.5 miles 3 5* 2.5 miles

. 4 30* 1.75 miles 5 180* 4.75 miles 6 50* 2 miles (viii). No monitors or samplers exist in these locations.

(ix). See (vii), above.

(x;. No monitors or samplers exist in this location.

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INTERROGATORY NO. 29-1(b). Please identify all radioio-dine-monitors or samplers at Harris in each of the locations (i) through (x) as stated in (a) above which (i) provide continuous sampling but cannot be read continuously; (ii) provide continuous sampling but must be manually read; (iii) provide continuous sampling but cannot be read without removal of a sample from the monitor or sampler; (iv) sample less than i continuously, giving the time periods or pattern of sampling for each; (v) are read other than continuously, providing the method and schedule of reading for each; (vi) provide readouts other than on a continuous basis, stating for each to what

places, displays, computers or other aquipment the readings are j provided,1or the data from such monitor or sampler is provided, and the schedule on which it is provided, and the minimum and maximum schedules on which such readout or data is checked by.a human being (and which person is to do that, by job description

or title if names unknown); (vii) provide other than continuous sampling and are read less often than (aa) once per hour; (bb) once per shift (6, 8 or other designated number of hours per I shift, stating the number of hours in each. shift and the title c or identity of the person to read same and whether plant '

procedures require such person to make such reading); (cc) once per day (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />), stating the title or identity of the person designated to read same and whether Harris plant procedures require such person to make such reading; (dd) once per week; (ee) once per tonth; (ff) once per quarter; (gg) once per year; i (hh) once per refueling cycle, stating the expected length of

such refueling cycle; (jj) less often than once per year or once per refueling cycle, stating the time interval specified i for such reading, and giving for each of (dd) through (jj) above the information who (name or job title) is designated by Harris plant procedures to make the reading, and whether the procudures require such person to make such reading within the time stated; (viii) for each. person (or job title) stated or li.sted in response to-(vii) above (and all parts or any part thereof), state what the level of radioiodine reading is at which that person must take additional action, and what action j plant procedures require that person to take if the radiciodine reading is at or above that level. (viii-aa) If there is more than one level of radiciodine reading at which a person making or checking the reading (per vii above's answers you have provided) would have to take a different action, please specify each such action and the minimum level of radiciodine reading that requires such action.

ANSWER. The information requested has not been tabulated in the form requested for in-plant and effluent monitors; however, the information is available in FSAR Sections 11.5.2.1 and 11.5.2.3.

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D Environmental surveillance is conducted offsite through the use of environmental samplers. All the environmental samplers listed in Applicants' response to Interrogatory 29-1(a) above sample air continuously. They are changed once per week. These samplers are read at the time of changing through laboratory analysis of the samples obtained. The analysis is performed by environmental' radiation laboratory personnel and the results are reviewed by the supervisor of that laboratory. The changing of sampler filters and the analysis of samples are conducted according to established and approved operations procedures for SHNPP. The technical ,

specifications and associated procedures, which have not yet been written, will specify required actions to be taken in the event radioiodine readings offsite exceed a specified level.

INTERROGATORY NO. 29-1(c). For each radioiodine monitor or sampler (or other radioiodine detector) identified in l response to any part(s) or (b) or (a) or both above, please l state (i) whether Applicants have independently determined the accuracy of such device, monitor, sampler or detector

(ii) if response to (i) above is affirmative for any such thing, state exactly how the test was done, what the acceptance criteria were, whether the acceptance criteria were established before, during or after the test, who established the acceptance criteria, the method of the test,.who conducted the test, and i the qualifications of each person who conducted the test or j established acceptance criteria for such test to perform such l . work or make such test or determine such criteria; and to j identify all documents which include the method (s), acceptance criteria, lab notes, results of such test, limits of accuracy l

of the test itself, limits of accuracy of the equipment used, calibration of the equipment used, assay of any radioactive material used in the test, calibration of any equipment used in L assaying the amterial used in the test, or potettial for error in the test as designed or as-conducted, including any devia-tions from the protocol or procedure for the test which acutally occurred during, before or after the test. (iii) If

response to (i) above is other than affirmative, please state whether Applicants have any information on the testing of each monitor identified in response to any part(s) of (a) or (b)

. above for accuracy (aa) under laboratory conditions, (bb) under plant operating conditions at any other nuclear plant besides

Harris, (cc) under other conditions, specifying such other

, conditions, giving this information for each such monitor, detector, sampler or device.

ANSWER. In-plant monitors and samplers will be calibrated

using NBS~ traceable standards in accordance with approved procedures. Each of the samplers identified under 29-1(a)(vii) above is calibrated for air flow using NBS traceable standards.

i The calibration is performed with a Kurz mass flow meter. The

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I Kurz mass flow meter calibrates the dry gas meters in the ,

sampling devices. This calibration results in a factor for

. each dry gas meter in.each sampling device. This factor is then used to set up the meters for sampling operations until

'the next quarterly calibration. The sampling devices with their dry gas meters are coupled to an analytical system. This l

analytical system is composed of a computer-based gamma l .

( radiation spectrometer. The analytical system is verified with l

l a quality control program and calibrated each day when it is in use. Should the test indicate that the analytical system performance is beyond control limits, the system is removed from service, evaluated and its performance brought within control limits.

The acceptance criteria for the equipment composing the analytical system are designated in' operational procedures.

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The criteria are selected and established by the environmental laboratory supervisor.

INTERROGATORY NO. 29-1(d). For_each monitor, detector, sampler or device identified in response to (c)(iii) above, please give all information requested for an affirmative response to (c)(i) above, which is requested in (c)(ii) above, i for each such device, monitor, detector or sampler on which

. someone other than Applicants have performed accuracy tests.

CBJECTION. Applicants object to the incomprehensible form of this question.

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INTERROGATORY NO. 29-1(e). What is the maximum level of '

contamination known to Applicants to have been found in or on any radiation monitor, detector, sampler or other device for detecting radioiodines, identified in response to the above interrogatories or any part thereof, during plant operations at

, any site other than Harris? (i) what contaminants were involved i -- which nuclides in what amounts or concentrations? (ii) how

'did these contaminants get to such monitor. Please note that this interrogatory applies to the same type and the same model of monitor, detector, sampler or other device for detecting radioiodines which is planned to be used at Harris.

ANSWER. " Contamination" in the sense of this contention I

is understood to be defined as a residual buildup of radioac-tivity which would lead to saturation or inaccurate instrument readings.

Applicants cannot specify a maximum level of contamination found in or on the type and model of radiciodine monitoring equipment identified above.

INTERROGATORY NO. 29-1(f). At what pages of the FSAR, in what amendments, have Applicants provided (i) the information promised in item 3 of page TMI-61 of the FSAR as current 5-14-82; (ii) the information for item IV, p. TMI-63 of the FSAR as referenced in (i) above, for steam generator safety relief valve, PORV, atmospheric steam dump valves, and release points of secondary steam from the auxiliary feedwater pump turbine, which is promised in the last paragraph on page TMI-63; (iii) information concerning.any other radioiodine release points or potential release points identified by Applicants or NRC staff or others since the TMI Appendix to the FSAR was drafted; (iv) information concerning any other radio-iodine release points or potential release points currently known to Applicants in the Harris plant (aa) as designed (bb) as built to date or currently. If any such information is not now in the FSAR, please identify that information, for items i, ii, iii, iv or any or all of the above.

ANSWER.

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(1). The information promised in Item 3 of page TMI-61 of the FSAR as it existed in May 1982 (subsequently superseded by Amendment 3) was supplied and is currently found in FSAR Section 11.5.2.5.11 (Amendment 3). Applicants do not, however, consider this information relevant to radiciodine releases or Appendix I compliance since the information relates to high-range monitors for noble gas effluents.

(ii). The information promised under item 4, page TMI-63 of the FSAR (superseded by Amendment 3) relating to high-range monitoring of effluents from pressure relief valves and atmospheric steam dump valves is found at FSAR Section 11.5.2.7.2.16 (Amendment 3). This information is irrelevant to Contention 29. See answer to (f)(i) above.

l (iii), (iv). Current or potential radioiodine release points or potential release points are identified in Tables 9.4.0-2 and 11.3.3-1 of the FSAR.

INTERROGATORY NO. 29-1(g). Identify the model number, type, manufacturer, and cost of each radioiodine monitor, detector, sampler or device for detection which is included in (i) the FSAR per-response to (f) above, or (ii) the responses to (a), (b), (c) or (d) above, which Applicants plan or expect to install, or have installed,.at Harris, stating at what location and for what purpose such monitor, detector, sampler or. device is installed or will be installed. (iii) For each such item, state whether CP&L or Applicants or their con-

- tractors or subcontractors are in possession of the item (monitor, detector, sampler, or other radiciodine detection device).

PARTIAL ANSWER / OBJECTION. The envd.ronmental samplers identified in response to Interrogatory 29-1(a)(vii) are

' Analytical Process Instruments, Inc. Model NRC-2000 Nuclear Air Samplers. CP&L is in possession of this equipment.

Information on in-plant monitors is not available in the form i

requested by the Intervenor. However, details concerning the I i application and use of.these monitors is contained in Chapters l 11 and 12 of the FSAR. Applicants object.to the identification of cost.concerning the devices discussed. Cost has no impact on the accuracy, functioning or ability of the devices to l

perform their allotted tasks and is irrelevant to the issue of i radiciodine release estimation or Appendix I compliance.

INTERROGATORY NO. 29-1(h). Are Applicants able to sample every release from (i) the condensate vacuum pump effluent (ii)

(_ the atmospheric steam dump valves -- each one, (iii) the steam ,

generator safety relief valves, (iv) the power operated relief l

1 20-

• l

-,w

-e--- . . - - - - - - - , ,rv4 - , . - - ,,.-n.- - , , , -

,-, - ,,,,-,n -

- , . , - , - - , . - - - - ,. --- ,-m

valves, (v) the AFW pump turbine potential release points, (vi) the other potential or actual radioiodine release points identified in (f)(iii) or-(iv) above, (aa) continuously for radioiodines? (bb) for (i) through (vi) above, other than continuously for radioiodines, stating how and how often such sample will be taken, and how many samples can be taken simultaneously and how many persons are required to take each such sample and how those persons will be shielded from -

radioactivity. (cc) please identify, for each release point in (i) through (vi) above, which nonsampling monitors or detectors will be used at Harris for each such point, whether such device (s) are mobile or fixed at each such point, and how many mobile devices for such use are available at Harris and how many persons are required to use each such mobile device.

ANSWER.

(i) There is no condensate vacuum pump. Applicants will

~

! be able to sample every release from the condenser vacuum pump effluent.

i i (ii) Applicante are not able to sample the atmospheric steam dump valves.

l l

l (iii) Applicants are not able to sample the steam i

generator relief valves. * -

(iv) Applicants are not able to sample the power operated relief valves.

(v) Applicants are not able to sample the AFW pump turbine potential release points.

(vi) Applicants will be able and in fact will be required to account for all radioactive releases (including radiciodine)

-to-the-atmosphere. The radiological monitoring system, l-

._- _- _-__ - _ __ .-_ _ _ _ _ . _ _ _ . _ _ . . -_ __, _ __ _ .,,-- - ,=-- _ - _ _ . . _ . - , _ -_ - - - - - - - - . . .

=. - ._ - . --

including in-plant and effluent monitors provides the data necessary for this accountability. The environmental moni-4 toring system provides a back-up to this accountability.

INTERROGATORY NO. 29-1(j). ("i") is not used due to possible confusion with other parts). (i) Identify all documents'in the possession of Applicants which give actual or estimated radioiodine release rates or total amounts (per year or otherwise) for operating nuclear power plants, particularly VC Summer, North Anna 1, North Anna 2, Robinson 2, Brunswick 1, and Brunswick 2.

(ii) if known to Applicants, please state for each plant for which Applicants possess any data on radioiodine I releases, whether the monitoring of radioiodines for that plant is continuous at all points of release,. including for PWRs every point of release identified in, or in response to, any part of (h) above; (iii) please, if known to Applicants, state t the accuracy and testing for accuracy which each radioiodine '

monitor, detector, sampler or other device at any plant listed in (1) above or identified in response to (i) or (ii) above has

-been during the entire time for which Applicants have radioio-dine release data for that plant, or any part thereof, specify-ing such part of such time, providing all this.information for each plant; (iv) If answer to any part (i), (ii), (iii) or i- subpart above is other than affirmative, please so state, giving any basis for such answer, and stating which questions or parts of questions above Applicants do not know the answer to.

ANSWER.

(1). Applicants possess copies of the semi-annual reports which are required by the NRC on actual radioiodine releases at the' Robinson and Brunswick Plants. In addition, the reports listed below contain radioiodine release information on U.S.

nuclear power plants:

I  !

i

Effluent Release Documents U.S. Plants

1. NUREG 0367, Radioactive Materials Released from Nuclear Power Plants (1976)

2. NUREG 0521, Radioactive Materials Released from Nuclear Power Plants (1977)

3. NUREG 1497, Radioactive Materials Released from Nuclear Power Plants (1978)

4. NUREG 2227, Radioactive Materials Released from Nuclear Power Plants (1979)

5. NUREG 2907, Radioactive Materials Released from Nuclear-Power Plants (1980)

Applicants, however, view these reports as irrelevant to ,

Contention 29. These reports were not used to calculate the radiciodine source term, estimate radioiodine releases or determine Appendix I compliance.

OBJECTIONS.

(ii). Applicants object to the provision of this informa ,

tion. Whether monitoring is continuous or not at other plants-has no bearing on the estimation of radioactive releases at SHNPP and consequently is irrelevant to Contention 29, espe-cially since such data was not used in the derivation of the iodine source term or other Appendix I calculations. See Applicants' response to Interrogatory 29-1(p).

(iii). Applicants object to the provision of this information. See (ii), above.

.-~ . - . _.

(iv). Applicants object to the provision of this informa-tion. See (ii), above.

INTERROGATORY-NO. 29-1(k)(i). Have Applicants performed any tests of (aa)' vole thyroids (bb) mouse thyroids (cc) rabbit thyroids (dd) deer thyroids (ee) sheep thyroids (ff) cattle thyroids (gg) human thyroids (hh) thyroid glands of any other species,: stating which species, in order to establish baseline or background levels of radioiodine around and at the Harris l plant site? (ii) If answer to any part of (i) above is l affirmative,.please state who performed the tests, when, what that person's qualifications were to perform such test, where -

the organisms whose thyroids were tested came from (location and distance from plant site; within the plant site, distance from the nearest release point identified.either in FSAR pages TMI-60 through -63, or other release point identified in response to any part of (h) above), what test was done, the method of such test (or tests),_the equipment used in each such ,

test, its calibration, derivation of background counts, sampling technique (s), counting equipment used, how long the counting was done for both samples and background counts, when the sample counts were performed, when the background counts were performed, all results of such tests, identify all documents, lab notes, data sheets, data recordings, printouts, and other records of each such test, and explain why the l method (s) or test (s) used were selected. (iii) Do Applicants know if anyone else has performed tests on the thyroids of any species inquired about in (i) above within 50 miles of the Harris site (aa) prior to 1970 (bb) prior to 1974 (Oconee plant 1 operation) (cc) prior to 1975 (Brunswick 2 operation) (dd) prior to 1977 (Brunswick 1) (ee) prior to 1981 (McGuire 1

operation; (ff) after 1-1-81;-(gg) after 12-1-81. (iv) If response to any part of (iii) above is affirmative, identify such person and state if known, what tests were done by that person and when. If the data of tests dones by any person known to Applicants to have tested thryoids of any species l within 50 miles of Harris is unknown, please identify the

, person and say that the~date of the tests is not known. (v) Do

[ Applicants have a position as to whether radiciodine levels in i

thyroids are an appropriate measure of'radioiodine levels to which organisms in the environment are exposed? (vi) If answer to (v) is affirmative, please state Applicants' position.

l (vii) Do Applicants know whether any other electric utility has taken a position concerning whether radioiodine levels in thyroids are an appropriate measure of radioiodine levels to which humans and/or other organisms in the environment are eFposed. (viii) if answer to (vii) iS affirmative, please identify each such electric utility and state its position or identify any document in which such position is stated.

L -

a ANSWER.

(

(1). No. (ii). Not applicable. (iii). No. (iv). Not applicable. (v). Yes. (vi). Direct measurement of radioio-dine levels in animal thyroids is not an appropriate monitoring technique to adequately control and maintain compliance with 10

,CFR 50, App. I, which applies to human thyroid doses. Effluent

^

release monitoring and sampling backed up by environmental monitoring and employee whole body counting programs provide the most sensitive surveillance for potential public exposure to environmental radiciodine. (vii). No. (viii). Not applicable.

INTERROGATORY NO. 29-1(m). Do Applicants possess any data as to the amount of radioiodines detected in the environment within 50 miles of (i) their Brunswick plants (aa) on land (bb) in rivers (cc) in the ocean (dd) elsewhere within 50 miles of (ii) within 50 miles of the HB Robinson F L,plant; Brunswick plants; (iii) within 50 miles of the VC Summer nuclear plant; (iv) within 50 miles of the North Anna nuclear plants; (v) within 50 miles of any Westinghouse PWR plant not inquired about above in (ii), (iii), (vi) within 50 miles of any power

.. plant which uses the same types of models of radioiodine monitors which Applicants plan to (or have installed) install at Harris? (vii) If the answer to any of parts (i) through (vi) above is affirmative, please state the identity of the plant, identify the data Applicants possess, and identify all

.  : documents Applicants possess which contains such data.

ANSWER.

(1),(ii). Applicants possess annual radiological surveil-

[ lance reports for the Brunswick Plant and Robinson Plant.

These reports summarize the amount of radiciodine detected in 5

a .

- ._ .. - . . ~. . - . ._ -- .. .-

e the surrounding environment-for the year specified.

(iii)-(vi). No. (vii). Not applicable.

, INTERROGATORY NO. 29-1(n). Do Applicants-know whether the i

same (1)' type (ii) models (iii) series (iv) design of radicio-dine (aa) monitor (bb) detector (cc)_ sampler.(dd) other detection device used or to be used at Harris are installed at any other nuclear power plants (xx) in the US'(yy) outside the US? For each response to the above 4 by 4 by 2 element set of

, questions, if the response is affirmative, please identify each power plant.and which type, model, series, or design of radiciodine detection device (including monitors, detectors and samplers) is used there. The insertion in the third line of this interrogatory reads ~"used or to be used at Harris" and follows the word " device" in that line. That should clarify the question, as it is not clear the insertion will be readable otherwise.

ANSWER. No.

INTERROGATORY NO. 29-1(o). Do Applicants know of any operating nuclear power plant (i) in the US, (ii) outside the US, for which every possible release point for radio-iodines is continuously monitored? (iii) if answer to (i) or (ii) above ils affirmative,'please identify such plant and all documents in possession of Applicants which confirm or support such answer;

(iv) if. App 1& cants answer to either (1) or (ii) above is negative, have Applicants inquired as to this matter of

continuous radioiodine monitoring at all possible release points for-any nuclear. plant? (v) If' answer to-(i) above is other.than affirmative, please answer question (iv) above also,

'if answer is not already given, (vi) please list every utility or power plant for which Applicants have inquired about

-radiciodine monitoring at, in any way, since March 28, 1979.

(vii) For each plant or utility listed in response to (vi)

I above, please state the inquiry'made, how made, when made, by whom made, and the answer or response received, identifying all documents which contain such inquiry or response or were supplied in response to such inquiry.

ANSWER. Applicants have no knowledge of any such plant and have made no inquiries on this subject.

T

., . , . , .n.- ,v . , , - , - . , . . , . , - ,...,c,,n.. , , , . . ,

INTERROGATORY NO. 29-1(p). Please state exactly how Applicants derived their revised iodine source term conveyed to

'NRC Staff, including (i) whether there was any change in assumed core inventory of radioiodines in making this revision (ii) if answer to (i) above is affirmative, the exact changes made, and all reasons for making such changes, and all docu-ments, experts, opinions and other information relied upon in making'such change; (iii) whether there was any change in the transfer of radioiodines assumed in revising the source term; (iv) If answer to lii is affirmative, what changes were made,

why,-all reasons for making each such change, and all'docu-ments, experts, opinions and other information that were used in making each such change (v) the derivation of the core inventory of radiciodines, and all experiments, analyses, calculations, and other basis of such core inventory that are known to Applicants for radioiodines; (vi) any assumptions about radiciodines used in deriving Applicants' source term which is currently being used in this case, which have not been identified above, stating for each who made the assumption or computation, and the full basis for such assumption; (vii) all other facts used in deriving the radiciodine terms (each of

• them) in the source term currently in use in this case.

ANSWER. The iodine source term in the context of Contention 29 is defined as the estimated annual quantity (in curies) of the iodine isotopes released'from the SHNPP in i

liquid and gaseous effluents. As stated in Chapter 11 of the SENPP FSAR, the guidance presented in NUREG-0017, " Calculation l of Releases-of Radioactive Materials in Gaseous and Liquid f

Effluents for PWRs" (April 1976) was followed. NUREG-0017 makes use of the " standard plant" approach in developing a plant-specific source term. That is, values of primary and secondary coolant activities have been developed for a "stan-dard" plant based upon values of certain design parameters such as, for example, power level, mass of reactor. coolant, etc.

The calculation of the coolant activities for any given plant l

is based upon applying adjustment factors to the " standard" l

~ _ _ - _ _ _

coolant concentration values. These so calculated plant-specific coolant concentrations are the basis for the source term. The above method, described in greater detail in US NRC's NUREG-0017, was used in calculating the SHNPP iodine source term, as presented in the FSAR. The above method does not make use of the iodine core inventory.

With respect to the question of changes in the calculated iodine source term, while the same guidance was followed in developing the liquid iodine sourco term presented in the SHNPP PSAR and FSAR, the FSAR liquid source term was revised to reflect primarily certain changes in the design of the liquid radwaste system and expected operational modes. For example, the ESAR liquid iodine source term was calculated without taking credit for the use of evaporators in the Equipment and Floor Drain Systems. As such, the conservative assumption of not using the evaporators in these systems on a routine basis resulted in a higher liquid iodine source term as presented in the ESAR.

The PSAR-gaseous iodine source term was developed using the guidance of Reg. Guide 1.42, which has since been with-

, drawn. The gaseous iodine source term contained in the FSAR was developed using NUREG-0017.

INTERROGATORY NO. 29-1(q). (i) Do Applicants have any information concerning the breakdown of or any failure of filters or other devices used to remove radiciodines from any nuclear power plant's effluent streams prior to release into I

. ~

the environment; (ii) If answer to i is affirmative, please state such information and identify all documents in possession of Applicants which contain such information; (iii) Do Applicants have any information on the failure of sealers or gaskets in connection with any failure or breakdown identified in (i) above? (iv) if. answer to-(iii) is affirmative,.please identify all such information and all documents containing it, and state such information succinctly. (v) What is the exact limit on radioiodine releases for each isotope of iodine during normal operation of the Harris plant per (aa) technical speci-fications as proposed by Applicants (bb) technical specifica-tions proposed by NRC (cc). license condition Applicants plan or expect to accede to; (dd) plant procedures; (ee) please state which limits identified above are enforceable by NRC; (ff) please state any other limit for each radiciodine isotope, or all radioiodine isotopes together, for emissions from the Harris plant, which Applicants believe or know will apply to Harris, in curies per year or any other appropriate measure in which such limit is expressed.

ANSWER. (1). Applicants have no information concerning the breakdown or any failure of filters or other devices used

, to remove radioiodines from any nuclear power plant's effluent i streams prior to~ release into the environment.

(ii). Not applicable.

(iii). The Applicants have-no information on the failure l

of sealers or gaskets in connection with any failure or breakdown of filters.

(iv). Not applicable.

(v)(aa). The technical specifications for Harris are stipulated in dose, not in release, rates. The technical specifications are as follows. The dose to an individual from radioiodines and ra;ioactive materials in particulate form, and i

I

radionuclide (other than noble gases) with half-lives greater

, than 8 days in gaseous effluents released from each unit, from the site shall be limited to the following:

a. During any calendar quarter: less than or equal to 7.5 mrem to any organ and,

b. During any calendar year: less than or equal to 15 mrem to any organ.

For liquid releases:

a. During any calendar quarter, less than or equal to 1.5 mrem to the total body and to less than or equal to 5 rem to any organ.

b. During any calendar quarter, less then or equal to 3 mrem to the total body and less then or equal to 10 mrem to any organ.

(bb). For gaseous and liquid releases the NRC stan-dardized technical specifications are outlined in Sections II.C., III.A., and IV.A. of Appendix I to 10 C.F.R. 50.

(cc). All of (aa) and (bb), above.

(dd). The plant operating procedures will adhere to the technical specification limits.

9 (ee). Effluent limits stipulated in the operating 1

technical specifications are enforceable by the NRC.

(ff). The only limits for radioiodine emissions from the Harris Plant of which Applicants have knowledge are those i

stated in the Harris Plant's proposed operational technical specifications.

! INTERROGATORY NO. 29-1(r)(i). Please list the contribu-i tion to the Harris source term for each radioiodine isotope from each release point identified above, including all those

mentioned in pages TMI-60 through TMI-63 of the FSAR as it stood 5-14-82, and all those additional release pathways

identified in response to interrogatory (f)(iv) above or ,

otherwise known to Applicants at present. (ii) For each

' pathway (i.e. pathway passing through a release point inquired about in (i) above) for which the amount of radioiodine passing i through that point is not known- for any radiciodine -isotope, please list that isotope and state that Applicants do not know the amount of (isotope) released through that point or pathway.

e.g. Applicants do not know that amount of I-129 released through atmospheric steam dump valve 7" (if that is the case).

(iii) Please list all iodine isotopes not identified in the l Harris source term (iv) please list all isotopes of elements l other than iodine, which are produced in nuclear fission or

, expected to be produced by_the Harris core, which decay in any l, proportion into radioiodine isotopes. (v) For each isotope l listed in response to (iv) above please state the halflife of the decay into radioiodine (aa) directly (bb) into any other isotope which eventually decays into a radioactive isotope of iodine, and please state the. proportion of decays identified above (for each such decay) that (cc) result in a radioiodine isotope, or (dd) result in an isotope which decays further by one or more steps into a radioiodine, in any proportion. (vi)

Please identify which of the isotopes identified in response to (iv) above will be released from Harris, stating which are in the current Harris source term and which are not.

ANSWER. The isotopic effluent releases for SENPP are given in FSAR Tables 11.3.3-1 and 11.2.3-1 for all potential l radioactive gaseous and liquid pathways, respectively. For the

release pathways identified to be of concern in this paragraph of the interrogatory, the release points given in TMI pages TMI-59 through TMI-63 correspond to Table 11.3.3-1 as follows:

Table 11.3.3-1 TMI-59 to TMI-63 Release Source Point Number Containment and Reactor Auxiliary Building 1 Condenser Vacuum Pump (one per unit) 3, 4 Waste Gas Decay Tanks 5 For the above release pathways, only I-131 and I-133 have been identified. These two radionuclides are by far the most radiologically significant isotopes of iodine. The other iodine isotopes (I-127, I-129, I-132, I-134, I-135) have not been considered in the source term and radiological exposure evaluations because of their negligible contribution (less than

~4 In addition, the iodine source term 1 x 10 Ci/yr).

consists only of primary fission products, in accordance with NUREG-0017. That is, only those produced as a result of the fission process and not by the decay of other radionuclides.

The fission products expected to be present in the SHNPP core are common to all pressurized light water reactors. The information requested in this interrogatory is therefore generic. There are several source documents which list data on fission products.

For example, - _ -see the reference document._ _.-

Tables of Isotopes, by C. M. Lederer, J. M. Hollander, and

I. Perlman, 6th ed. New York: Wiley 1967. This is an extraordinarily detailed collection of nuclear data which includes the information requested in this paragraph of the interrogatory.

INTERROGATORY NO. 29-1(s). Please identify all (i) gaskets (ii) seals (iii) flexible mounting material (iv) other mounting material (v) other components, which are used or to be used in (or to seal) the air streams at Harris which may contain or are expected.to contain radioiodines, or which are adjacent to any traps, filters, or other devices for removing radiciodines from Harris gaseous effluents, which are made of (aa) polyethylene, (bb) polyvinyl chloride (PVC) (cc) ethylene propylene rubber (dd) neoprene (ee) crosslinked polyolefin 4

material (ff) chloroprene (gg) chlorosulfonated polyethylene.

ANSWER. The air cleaning system and piping systems, including the volume reduction system, are applicable to this interrogatory. The following list identifies all (i) gaskets (ii) seals (iii) flexible mounting material (iv) other mounting i

material (v) other components, which are used in the Shearon Harris air cleaning units.

i' C

(i) - Gaskets J Component Gasket Material HEPA Filter- Neoprene Profilters Neoprene Access Doors and Electric *Cohrlastic R-10480 Gr.

Heating Coils Medium Silicone Rubber Butterfly Valves Closed Cell Neoprene i

(ii) Seals Component Seal Material HEPA Filters (for all units *Self extinguishing rubber except Nos. E-4 and S-1) based HEPA Filters (for Units E-4

• Solid Urethane

.and S-1)

Prefilters

• Fire Retardant Foam (iii) Flexible Mounting Material Not applicable to the Shearon Harris air cleaning units

~

1 (iv) Other Mounting Material

~

Component Material Mounting Frames for Filters, ASTM-A276 304 Demisters and Electrical stainless steel Heating Coils (v) Other Components Component Material

~

CasingL(10,000 CFM cr less and ASTM-A240 304

-units'in-Containment Building) stainless steel Casing (above'10,000 CFM) Carbon Steel ASTM-A-36 HEPA Filter Frame Cadmium Plated Steel e--

,e , , .- . . - , - , - --,_-.-.4, w --,--re--w---, , m---e+-tm, e- -- -- ,yy

Component Material HEPA-Filter Separator Aluminum Type 1145-H19 HEPA Filter Face Guard Galvanized Steel Screen Prefilter Frame Galvanized Steel Demisters 304 stainless steel Charcoal Absorber 304 stainless steel l

l Duct work Galvanized Sheet Metal I

i

• NOTE: Material is supplied by the vendor in accordance with the vendor's standard practices and operational experience.

i (i) and (ii) .The following list identifies the gaskets / seals utilized in the off-gas filters of the Volume Reduction System:

Component Gasket Material HEPA to Charcoal Absorbers Neoprene Filter Access Doors Neoprene Valves and Blind Flanges for Flexitallic Style CG Test Ports Stainless Steel, Asbestos Filled i

l The following is a list concerning the requested information l

l for gaskets in other piping systems. (Items (ii) through (v) are not applicable to piping systems.)

l

For all systems, gaskets conform to the requirements of ANSI B16.5. Gasket dimensions and materials withstand bolt loading without injurious crushing.

For systems having design pressures of 250.psig or less, )

gaskets _are made out of compressed asbestos in accordance with ANSI B16.21, such as Garlock No. 900 or Purchaser approved' alternate.

For all systems having a design pressure greater than 250 psig, gaskets are spiral wound type 304 stainless steel ,

with asbestos fill such as Flexitallic Style CG or Purchaser approved alternate.

For stainless steel systems only the packing material has halide content not to exceed 200 ppm or will consist of asbestos with the addition of 20 percent by weight of sodium silicate.

INTERROGATORY NO. 29-1(t). Identify (i) all components identified in response to (s) above for which Applicants have performed any analysis of (aa) swelling (bb) embrittlement (cc) reduced elasticity (dd) reduced tensile strength (ee) oxidation (ff) oxidation in conjunction with radiation and heat (gg) swelling associated with heat, radiation, and reduced' oxygen -

(hh) uptake of moisture (ii) permeability to radioiodines (jj)

!~ diffusion rate of radiciodines in such material. (ii) all documents Applicants possess which provide any analysis of the above for any material listed in (s) above, with respect to any matter in (i) above.

( ANSWER. The Applicants have not performed any analyses l

specified in Interrogatory 29-1(t) on the components identifed in response to Interrogatory 29-1(s). Analyses of this type are performed by the vendors who supply the particular compo-nents. The Applicants specify design bases, conditions, and

. i l

l l

I performance criteria in order to meet NRC and applicable functional requirements.

INTERROGATORY NO. 29-2(a). Please specify the accuracy of the wind speed indicator used to collect meteorological data at the Harris tower for use in the ER and licensing of the Harris plant.

ANSWER. All sensors used by CP&L meet or exceed the requirements of NRC Regulatory Guide 1.23, Rev. O, 02/17/72.

The following are the requirements of Regulatory Guide 1.23 as stated on page 23.3 of the document:

1. Wind direction accuracy for instantaneous recorded values plus or minus 5 degrees.

2. Wind speed accuracy for time averaged values plus or minus 0.5 mph. Starting speed of anemometer less than 1 mph.

CP&L has used as the primary instrument for recording wind velocity and direction, a Meteorology Research, Inc. Model 1074-22 anemometer. This instrument has the following spe-cifications:

i Wind Direction Starting Threshold 0.75 mph Delay Distance 4 ft. (50% Recovery)

-Damping Ratio 0.5 to 0.6 Accuracy + or - 2.5 deg.

Wind' Speed Starting Threshold 0.75 mph Response Distance 18 ft. (63% Recovery)

Flow Coefficient + or - 0.25 mph Range 125 mph Maximum INTERROGATORY No. 29-2(b). Please state when such accuracy was last tested, and how, and what the accuracy was at

(i) wind speed below 1 mph; (ii) wind speed 1-4 mph (iii) wind speed 5-9' mph (iv) wind speed 10-14 mph (v) wind speed 15-19 mph (vi) wind speed 20-24 mph (vii) wind speed 25-29 mph, f

(viii) wind speed 30-39 mph, (ix) wind speed 40-49 mph (x) wind speed 50 mph and over; (xi) any other specific wind speed at which accuracy was tested. Please give the accuracy as determined, whether that is in percent, plus or minus speed, of however it was determined, in whatever units accuracy was determined.

ANSWER. Since all atmospheric dispersion computations ,

! have been performed using lower level wind sensor data, it is assumed that the question is~ directed towards the wind sensor located at the lower level on the SHNPP meteorological moni-toring tower. Refer to Table 29.2.A for the date last calibra-ted. All sensors have been returned to the original equipment manufacturer with instructions that tests were to be made upon the instrument to assure that the sensor meet original manufacturer specifications and then before return to CP&L, a wind tunnel test be conducted upon the sensor, providing data i

' of the test results.

t INTERROGATORY NO. 29-2(c). Please state when such accuracy (per (a) above) was first tested, by whom, by what method, and what the results were, including responses to items (i)~through (xi) of (b) above for this first test.

ANSWER. See Table 29-2.A, attached.

4

INTERROGATORY NO. 29-2(d). Please identify all documents which incorporate data or results of tests inquired.about in a, b, or c above.

ANSWER. The SHNPP Meteorological System Calibration Reports incorporate the results of the tests inquired in a, b, or c.

INTERROGATORY NO. 29-2(e). Please state how the accuracy of the wind direction indicator at the Harris site has been tested, and when, and what accuracy was determined for it, at all times of testing of its accuracy since such indicator began operating.

ANSWER. The basic instrument design must meet or surpass

.all requirements of NRC Regulatory Guide 1.23 for the wind direction sensor, provided instrument bearings were within the range of original manufacturer torque specifications. During each semi-annual calibration,. instrument bearings are replaced before the instrument is returned to the original equipment manufacturer for re-calibration. The manufacturer torque tests the wind direction sensor, assuring that original spe-cifications are met, thus assuring that the wind direction sensor will perform as intended.

INTERROGATORY NO. 29-2(f). If more than one wind direc-tion indicator, or more than one wind speed indicator, has been used for Harris meteorological data, please cnswer all parts and subparts of a through e above for each such indicator, identifying the indicator and its time in use (starting and ending date and time) if such information is not already given above.

ANSWER. A second wind. sensor is located at the top of the meteorological monitoring tower at SHNPP and recorded informa-tion.during the time period specified in Table 29-2.B.

INTERROGATORY NO. 29-2(g). Please state all sources of.

meteorological data in possession of CP&L other than Harris

, tower weather data, which were used by Applicants in computing-or estimating radioiodine concentrations.in the environment during Harris operation.

ANSWER. The onsite meteorological data was compared with information from the Raleigh-Durham Airport and other coopera-tive weather stations in the area (see references contained in

^

Section 2.3 of the SHNPP FSAR) to assure that the collected on-site data is representative of the collected onsite data, but only the SHNPP Meteorological Tower information was utilized in computing' dispersion estimates for plant operation.

I l

L i INTERROGATORY NO. 29-2(h). Please identify all documents in. Applicants possession which give the. time, amount, duration, intensity, or other information concerning rainfall or' snowfall or other precipitation for any Aucation or locations within 50

! miles of the Harris plant, indicating for each the year and date such information begins, the location, the method by which th& data'was collected, and any determination of the accuracy of-such data which Applicants have'made.

ANSWER. Please refer to the references cited in SHNPP FSAR Section 2.3 and SENPP ER Section 2.3. Additionally, the following are in the Applicants' possession:

1. " Persistence of Precipitation at 108 Cities in the t

Conterminous United States," D. L. Jorgensen and William H.

Klein, ESSA Technical Memorandum WBTM TDL 31, Systems Development Office, Environmental Science Services

l l

Administration, U.S. Department of Commerce, Silver Spring, Maryland, May 1970.

~

2. . " Effects of Tropical Cyclone Rainfall on the Distribution of Precipitation Over the Eastern and Southern United States," G. W. . Cry, ESSA State Climatologist, ESSA Professional Paper 1, Environmental Science Services Administration, U.S. Departmei: of Commerce, Washington, D.C.,

June 1967.

3. " Maximum Recorded United States Point Rainfall for 5 Minutes to 24 Hours at 296 First-Order Stations, Technical Paper No. 2," A. H. Jennings, Cooperative Studies Section, Hydrologic Services Division, Weather Bureau, U.S. Department of Commerce, Washington, D.C., revised 1963.

4. " Normal Monthly Number of Days with Precipitation of 0.5, 1.0, 2.0, and 4.0 Inches or More in the Conterminous United States, Technical Paper No. 57," J. F. Miller and R. H.

Frederick, Special Studies Branch, Office of Hydrology, Weather Bureau, U.S. Department of Commerce, Washington, D.C.,

1966.

5. " Maximum Station Precipitation of 1, 2, 3, 12, and 24 Hours, Part XI: North Carolina,' Technical Paper No. 15,"

Division of Hydrological Services, Hydrometeorological Section, U.S. Department of Commerce, Washington, D.C., 1955.

6. "Two- to Ten-Day Precipitation for Return Periods of 2 to 100 years in the Contiguious United States, Technical Paper No. 49," J. F. Miller, Cooperative Studies Section,

) Office of Hydrology, U.S. Weather Bureau, U.S. Department of Commerce, Washington, D.C., 1964.

7. " Rainfall Frequency Atlas of the United States for Durations from 30 Minutes to 24 Hours and Return Periods from 1 to 100 Years, Technical Paper No. 40," D. M. Hershfield, Cooperative Studies Section, Hydrological Services Division, l U.S. Weather Bureau, U.S. Department of Commerce, Washington,

• D.C., May 1961.

l 8, " Maximum 24-Hour Precipitation in the United States, l Technical Paper No. 16," A. H. Jennings, Hydrometeorological Section, Hydrological Services Division, U.S. Weather Bureau, -

U.S. Department of Commerce, Washington, D.C., January 1952.

In' addition to the above listed information, CP&L maintains records of climatological data published by the l

.,. - ,-.y , _ . . - , _ , , . , _ - - . - - .e , . _ , , , . ,p. , .9 w e - - . . .

National Climatic Center-in Asheville, North Carolina. The attached figure (Figure-29-2.A) is taken from the back of the most recent publication and indicates locations of precipita-tion and temperature recording stations in North Carolina.

"This publication contains-a daily recording of precipitation and maximum and minimum temperatures for cooperative stations around North Carolina. Applicants make no claim as to the completeness of the information or that all possible days, 4

months or years are available, from CP&L. All information is available from the National Climatic Data Center, National Environmental Satellite, Data, and Information Service, National Oceanic and Atmospheric Administration, U.S.

i Department of Commerce, Asheville, North Carolina, 28801.

INTERROGATORY No. 29-2(j). Please identify any data Applicants possess on the actual diffusion pattern of (aa)

I-131 particles (bb) I-129 particles (cc) other radiciodine particles (dd) organic iodine (ee) nonradioactive iodine particles (ff) non radioactive hypoiodous acid (gg) other forms of iodine around the Harris plant. Please identify all .

documents in which such data is contained and state how and

,l when and by whom such data was collected, , including methods i used and percent of iodine released that was traced, and any .

! data showing the distribution of iodine in (gg) air (hh) soil (ii) water (jj) buildings (kk) crops (11) forage or pasture (mm) grass (nn) other stopping points, e.g. cars, residences, schools, etc. that resulted.

ANSWER. Applicants possess no data on such actual patcerns.

t l

i l

INTERROGATORY NO. 29-2(k). Please identify any studies of the actual diffusion ,of (i) gaseous iodine (ii) air (iii) other gases, which Applicants have performed at the Harris plant, of (iv) which Applicants are aware of at any nuclear or other power plant. (v) Please identify all documents which contain the results or methods of such study for each such study, which Applicants possess or.are aware of.

ANSWER. Generic studies have been conducted to determine the diffusion of (i) iodine as a gas, (ii) iodine particulates, (iii) organic iodine, (iv) HOI, (v) other iodine products in the atmosphere. See " Iodine Species in Reactor Effluents and in the Environment" (EPRI NP-1269). The EPRI report concluded that the organic forms of iodine-131 persist in the environment and that the elemental form is rapidly converted to a less reactive form after the release to the environment.

I INTERROGATORY NO. 29-2(1). Please identify.any actual tests of diffusion of (i) iodine as a gas (ii) iodine particles (iii) organiciodine (iv) HOI (v) other iodine compounds which

, have been conducted (vi) from any release point of the Harris i plant identified in response to interrogatory 29-1 above,-or inquired about in interrogatory 29-1, e.g. at (f) therein, stating for'each test whether the iodine was radioactive or not, and if radioactive, what isotopes and.what amounts were released. (vii) Please identify all documents in which the methods of any tests, the results of any tests, or accounts or records of any _ test identified in response to items in (1) above (i through vi or any of them) are contained, who per--

formed the tests, who set the criteria for the test, who chose the method of the test, when the test was done, and who ordered the test.

i

! ANSWER. No such tests have been conducted.

INTERROGATORY NO. 29-3(a). Is the source term identified in response to 29-1(p) above the one used to derive the values for expected concentrations of radiciodines in the cooling tower blowdown (Table 5.2.2-3a) or main reservoir (Table 5.2.2.-3b) (ER) for Harris?

i I

1 ANSWER. Yes.

INTERROGATORY NO. 29-3(b). If answer to a is affirmative,  ;

is it for both or just one, and which one? i ANSWER. Both.

INTERROGATORY NO. 29-3(c). Is any of the concentration of radioiodines Applicants project for the reservoir or for the cooling tower blowdown due to atmospheric transport of radioio-dines?

ANSWER. No.

INTERROGATORY NO. 29-3(d). If answer to e is affirmative, please state exactly how much radiciodine which has been in the air before ending in the (i) reservoir and (ii) cooling tower blowdown.

ANSWER. Not applicable.

f INTERROGATORY NO. 29-3(e). Iden'tify all other release pathways or mechanisms whereby radiciodine can get into (i) the Harris reservoir, or (ii) the cooling water circulating through the cooling towers, stating for each all assumptions that affect Applicants estimate of the radioiodine released in each pathway, the reasons and data which support those assumptions, and the amount Applicants estimate will leak out through each such pathway (iii) for all radioiodines together, (iv) for each radioactive iodine isotope.

ANSWER. The release pathways already identified consti-tute the significant pathways that reactor effluents deliver doses to man during normal operations. There are no other release pathways presently known through which iodines can

! reach the cooling tower blowdown or-the reservoir while the' plant is operating under normal conditions.

INTERROGATORY NO. 29-3(f). Please identify all documents which Applicants rely on or have used in making calculations or in answering the questions above re radioiodine release from Harris to (i) cooling tower blowdown, (ii) the main reservoir,

-(iii) cooling tower circulating water, stating how each was used and what facts in each were re. lied upon.

ANSWER. As stated in response to 29-1(p), NUREG-0017.was-used to evaluate the radiciodine releases-(source term) for SHNPP. With regard to documents used-in the concentration calculations for the cooling tower blowdown and the main ,

reservoir, no specific guidance document was relied upon as this simple calculation only requires knowing the release rate of radioiodine into-the cooling tower blowdown, the blowdown discharge rate and the main reservoir volume in order to estimate the concentrations. The needed values are given in Section 11.2 of the SHNPP FSAR.

. INTERROGATORY NO. 29-3(g). Please identify all other information, expert opinion, or other facts not identified in response to any of (a) through (f) above which Applicants rely on or use in estimating radiolodine releases to the (i) reservoir, (ii) cooling tower circulating water (iii) cooling

', tower blowdown.

ANSWER. All information required to evaluate the radicio-dine liquid source term and the cooling tower blowdown and main reservoir concentrations is contained in Chapter 11 of the SHNPP FSAR.

4

INTERROGATORY NO. 29-3(h). What amount 1or curies of

-radioiodines do. Applicants project will.be released.from the-cooling towers at Harris other than by blowdown?

ANSWER. An. evaluation of radioiodines released from the cooling. towers other than by blowdown is neither required by the NRC nor has such an evaluation been performed.

~~

INTERROGATORY No. 29-3(j). Do Applicants plan to monitor the cooling towers for radioiodines?

ANSWER. Measurements for radioactivity in the cooling tower water will be made.

4 INTERROGATORY NO. 29-3(k). If answer to (j) above is other than affirmative, please state all reasons for your answer.

ANSWER. Not' applicable.

INTERROGATORY NO. 29-3(1). What effect does moisture in the cooling towers have on Applicants' ability to monitor radioiodines inside the cooling towers or in their release to i

the atmosphere? (ii) Do Applicants have any instruments capable of detecting radioiodines in the moist air / vapor / droplet mix to be found inside the cooling towers? (iii) Do Applicants have i any instruments capable of measuring radioiodines at the top of the cooling tower (s)? (iv) Please identify each such instru-ment, state how its accuracy varies with moisture as humidity and as water droplets, identify any tests substantiating such statements re accuracy variation with humidity and exposure to water droplets, for any instrument which is-inquired about in l (ii) cnr (iii) above and all'such instruments.

t

[ ANSWER.

I' l

- (i). Measuring the radioactivity in cooling tower water l

and knowing the-partition' coefficient between water and air (10,000-to 1), provides a more reliable and sensitive method of determining the radioiodine inside of, or escaping from the l

cooling tower than direct measurement of radioiodine in air.

(ii). No. 'See (1), above. (iii). No. (iv). Not applicable.

i INTERROGATORY NO. 29-3(m). (i) Does.tha release of liquid radioactive waste into the main reservoir at Harris count in Applicants estimates of radioiodines in the reservoir? (ii) If response to (i) above is affirmative, please state how much radioiodine, for each iodine isotope, is expected to be released into the reservoir as liquid (aa) per year (bb) over

-j the operating life of one Harris unit (cc) over the operating life of 2 Harris units, as estimated by Applicants. (iii)

Identify all documents and calculations'and assumptions made by Applicants in producing the information supplied in response to.

(ii) above, stating who made the calculations and assumptions, and what the basis of each assumption is, identifying also any documents which support the basis of each assumption. -(iv) Do the responses to (ii) and (iii) above use the:same source term Applicants identified and answered with respect to in Interrogatory 29-1(p) above?- (v) If response to (iv) is.other than affirmative, identify what source term was used and give

. its complete derivation. (vi) If not already identified in response-to (i) through (v) above, state all radiciodine g -pathways to the (aa) main reservoir (bb) cooling tower which

, Applicants have identified in their analysis of radiciodine i

releases- .

l ANSWER. The estimated annual releases of liquid radioac-l tive effluents are presented in Table 11.2.3-1 of the SHNPP FSAR. See answers to 29-1(p) and 29-3(a-g). These release values were used to calculate the radiciodine concentration in 1:

l the reservoir. The result of these calculations are shown in l

l FSAR Table 11.2.3-3. The basis for these values is given in 1

i Section 11.2.3 of the SHNPP FSAR.

i e -e,,, -,w .s n- w, , - , - -- -c,- e , .or,.e-,,,,,,- ---,n.,v,,.w-s- -,y --wa ----,.-w.,.,,,,,_ --,.,,--_, ,,- ,,_

m,,,w,--w,--,-. - ,, ,,---- ,

i INTERROGATORY NO. 29-3(n). (i) Please identify all documents which give (aa) test data, or (bb) operational data for nuclear power-plants of PWR type and Westinghouse NSSS (cc)

.or operational data for other PWRs, or (dd) operational data, for BWRs, showing the' amount or percentage of each radioiodine isotope which is trapped by (ee) the liquid radwaste processing system to be used at Harris, or a substantially equivalent system (ff) the-filters or radioiodine absorbers or traps to be used at Harris (gg) the substantial equivalent of such filters-(hh) the substantial equivalent of such absorbers (jj) the substantial equivalent of such traps. (ii) Please state for each document identified in response to (i) above how the radioiodine concentration was measured for each isotope (aa) before and (bb) after going through the radioiodine absorption device or system used (as described in i (ee) through (jj) above or otherwise, noting what other absorption device or system was used if it is not one of those in (i) above). (iii)

Please state the calibration method used, how long before the test it was used, and the accuracy found, for each device used to measure the radioiodine concentrations inquired about in (ii) above. If you don't know, please so state.

ANSWER NO. 29-3(n). Plants vary significantly in the components of the systems addressed in this interrogatory and in the modes of operation employed. Applicants have not analyzed available operational data in a way which would permit identification of documents responsive to the interrogatory.

Some applicable information may be available in NUREG-OO17, ,

" Calculation of Releases of Radioactive Materials in Gaseous &

Liquid Effluents from Pressurized Water Reactors" (April 1976),

which document speaks for itnelf.

l l

INTERROGATORY NO. 29-3(o). (i) Does CP&L possess a copy i~

of each document which describes the exact method CP&L used to calculate concentrations of radionuclides in the main Harris reservoir? (ii) If response to (i) is other than affirmative, please list each document which describes such method and state whether Applicants possess a copy of it. (iii) If response to (i) above is affirmative, please list each such document. (iv)

Please state how the method inquired about in (i) above was determined to be Applicable to the Harris reservoir, and what

i limitations the method has, if: any, (v) please state whether CP&L or-Applicants.have done any study of'the actual stratifi--

- cation or actual degree of annual turnover-in the Harris reservoir. (vi) If answer to (v).is affirmative, please identify each such study, who did it, when, any documents which (aa) request the study, (bb) plan the study (cc) include field notes or data from the study (dd) all results of the study (ee) all data collected'from such study. (vii) Have-Applicants done t

or had done any dye-tracer or other tracer study of the Harris reservoir and circulation of water in it? (viii) If answer to (vii) is affirmative, answer all parts of (vi) above for each' such study, and please also state what method, if any, was used

_ to simulate Harris plant water withdrawals and discharges in operation in such study, including the actual withdrawals and discharges of water made, or any assumptions involved in such simulation, for the study. (ix) Was any dye tracer study or other empirical study of Harris reservoir used by Applicants with_ respect to radioiodine level computations for the ER? (x)

If answer to (ix) is affirmative, please identify any such-l study not already identified in response to the above ques-

tions, and state for each all tie information requested in (vi) i above. Wherever information in (vi) is requested with respect to any answer other than that to (v), the language about (v) 1 being affirmative which is contained in ' die text of (vi) above

! should be ignored.

(1). Yes. -(ii). Not applicable. (iii). These calcula-tions are contained in an Ebasco calculation file. (iv). The 4

method used by Applicants is based on commonly accepted engineering principles. (v). Applicants have not. conducted any stratification or turnover study per se; however, profiles

, of temperature and dissolved oxygen (an indicator of stratifi-

cation)-are included in the Harris biological monitoring program conducted by CP&L biologists. (vi). Three reservoir stations were meas ~ured in situ monthly during 1982 as described i

above. These studies are continuing, with the number of reservoir stations expanded to five. (aa). (bb).

None. This

- program is described in Applicant's ER. (cc). The analysis of i

i  !

- _ -, . _ . , _ _ _ ~ _

l water quality. data from~the non-radiological monitoring. program. l has.not been completed. (vii). No. (viii). .Not applicable.

(ix). .No. -(x). Not applicable.

INTERROGATORY NO. 29-3(p). (i) Have Applicants performed any study analysis or experiments as to the chemical interac-

-tions or reactions or-(aa) elemental iodine (bb) organic iodine f(cc) HOI'(dd) other iodine compoundsiin either (ee) the Harris cooling tower system, or (ff) the' Harris reservoir? (ii) If answer to (i)(ee) or (i)(ff) above is affirmative, please identify any such study, analysis or experiment, state who did it, when, who ordered it, the methods used, identify all documents requesting the study,. planning it, giving the methodology used, stating the field notes or lab notes from such study, workpapers from the study or analysis or experi-ment, or which give the results.of such study, analysis or

experiment of the data used or collected in such study analysis or experiment. (iii) Please state exactly how the results of each experiment, study or analysis identified in response to (ii) above affects.the concentration of radioiodine in (aa) the Harris cooling tower blowdown (bb) the Harris reservoir (cc) the air above the cooling. towers when they are in use (dd) the air over the Harris reservoir, or air moving across the reservoir surface (ee) bottom sediment at Harris reservoir or in it. (iv) Please identify any studies Applicants have i

performed of radiciodine uptake of algae or aquatic weeds in the Harris reservoir or downstream of it, including all

~ documents that request or contain the results of such studies.

(v) Please identify any other studies of radioiodine uptake by

, -algae which Applicants rely on in their analysis of radioiodine

doses to humans from Harris. (vi) Please identify all informa-

! tion or studies on the water / air - aquatic weed - waterfowl -

human pathway for radioiodine uptake which Applicants have used or rely on for Harris. (vii) For each study identified in (v) l or (vi-) above please state who did it, when, whether Applicants I have any documents that contain the study, whether Applicants l have any documents-that contain the results, and identify all j documents containing information 1squested in this subsection

! (vii) as well as information requested in (v) or (vi) above.

l (viii) Please identify any information concerning iodine l-concentrations in food chains beginning with algae upon which Applicants rely in computing or estimating radioiodine doses to humans. Please provide all information in the second and third j lines (1st and 2d full lines) of vii above for all information-i identified in response to this subsection.

ANSWER.

(1). No. (ii). Not applicable. (iii). Not applicable.

(iv). No.such studies have been identified.

(v). As indicated in Section 11.2.3 of the SHNPP FSAR, radioiodine doses to humans were calculated in accordance with the models given in Regulatory Guide 1.109, " Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 C.F.R. 50, Appendix I". These models'are the results of numerous studies which have been performed on the environmental uptake of radionuclides. The evaluation of liquid effluent dispersion in the reservoir was performed based.on the guidance given in Regulatory Guide 1.113, " Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the

- Purpose of Implementing Appendix I". This guide relies on studies of dispersion mediums in which the radionuclides can be l

contained.

l l

l See-(v), above. See (v), above.

(vi). (vii).

l (viii). The only food pathway to man, involving algae, is l the water-fish-human pathway. The concentration factor fish /

l l water, given in NRC Reg. Guide 1.109, included the water-algae-fish concentration, and therefore provides the requested information.

l l

, . . , , . , , . ,,. , - . . , - - - , ,,- , , , , . . ,, ,, ,.,,a ~ ,,.,c .,

. )

-1

-INTERROGATORY NO.-29-4(a). .Do. Applicants consider a site emergency-at Harris to be included in " normal operation"?'

ANSWER'NO. 29-4(a). No.

INTERROGATORY NO. 29-4(b). .Do Applicants consider a general emergency at Harris to be included in " normal opera-tion"?

ANSWER. No.

INTERROGATORY NO. 29-4(c). Do Applicants consider a site alert at Harris to be included in " normal operation"?

~

ANSWER. No.

INTERROGATORY NO. 29-4(d). Do Applicants consider " normal operation" at Harris to include all conditions which are not defined-by NRC as emergency situations on one of the 4 levels (up to general emergency)?-

ANSWER. No.

/

INTERROGATORY NO. 29-4(e). What is the maximum condenser leakage possible at Harris in " normal operation"?

ANSWER. The SHNPP condensers will operate under negative pressure values exceeding those required to ensure adequate performance. Under these operating conditions,. leakage, if any, will be from the outside to the condensers. Consequently, the condensers are not expected to be a source of uncontrolled releases of radioactive effluents-to the environment.

7, ( - - =. _

u 5 E l

INTERROGATORY NO. 29-4(f).

What is the maximum primary to secondary system' leakage at Harris that is normal operation?

a ANSWER. The primary to secondary leakage shall be limited

1. to 500 gallons per day through any one steam generator.

There

.t

- isLno primary to secondary leakage value which is considered to be normal operation. The necessary steps required in the f .>

Technical Specification (TS) action statements together with the surveilIance requirements will ensure that leakage in excess of,che TS value does not occur. See FSAR Section 16.2.

INTERROGATORY NO. 29-4(g). What is the maximum primary to ,

secondary <' leakage at Harris for which the plant can continue to operate (i') indefinitely (ii) for more than one week (iii) for more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (iv) for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (v) for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (vi) for 24 to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (vii) for less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />? (viii)

Please statt'any power limitations that apply to the responses

~

to (i) throng:i (vii) or any of them.

ANSWER. Operation of SHNPP will continue as long as the primary ty secondary leakage is within the TS leakage value as stated in (f),above. With the primary to secondary leakage greater than'the limit given in (f) above, the TS requires that the leakage rate be reduced to within the limit within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

, or,be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in

! t cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. See FSAR Section 16.2.

INTERROGATORY NO. 29-4(h). What is the maximum radioio-dine level in primary coolant allowed at Harris in normal operation?

i

. , , - . . - - . , - . , -. ~ ,- - - - , - - - - - - - - - - - - . - - - ~ - - - -

. l I

l ANSWER. If the specific activity of the primary coolant exceeds 1.0 microcurie per gram dose equivalent I-131 but remains.within the limits specified in Figure 3.4-1 of the FSAR, operation may continue for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> provided that the cumulative operating time under these circumstances does not exceed 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in any consecutive 12 month period. If the total cumulative operating time at a primary coolant specific activity greater than 1.0 microcurie per gram dose equivalent I-131 exceeds 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> in any consecutive 6 month period, Applicants must prepare and submit a Special Report to the Commission within 30 days indicating the number of hours ,

above this limit.

If the specific activity of the primary coolant exceeds 1.0 microcurie per gram dose equivalent I-131 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during one continuous time interval or exceeds the limit line shown on Figure 3.4-1, the plant must be in at least hot standby with average reactor coolant temperature less than 500*F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

INTERROGATORY NO. 29-4(j). Is there any level of radioio-dine or of any isotope of iodine in Harris primary coolant that l

requires or forces the plant to be shut down, by rule, proce-dure, or otherwise?

ANSWER. Yes.

INTERROGATORY NO. 29-4(k). If answer to j above is affirmative, please state each such level that may require the Harris plant to shut down, giving the highest such level which

requires plant shutdown (i) by NRC regulation (ii) by plant operating license condition (iii) by plant operating procedure (iv) otherwise.

ANSWER. See Applicants' answer to Interrogatory 29-4(h),

above..

INTERROGATORY NO. 29-4(1). Is there a minimum or maximum level of radiciodine in the Harris condenser which would require the plant to shut down?

ANSWER. Yes.

INTERROGATORY NO. 29-4(m). If answer to 1 is affirmative, what is that level, and is it a maximum or a minimum?

ANSWER. The specific activity of the secondary coolant system must be less than or equal to 0.10 microcurie per gram dose equivalent I-131. With the specific activity of the

secondary coolant system greater than 0.10 microcurie per gram l

dose equivalent I-131, the SHNPP TS require the plant to be in at least hot standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within l

the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. See FSAR $ 16.2.

I INTERROGATORY NO. 29-4(n). What is the maximum amount of fuel or percentage of fuel that can fail (i.e. be leaking from fuel rods) at Harris (i) without the plant being shut down by NRC rule or regulation (ii) without the plant being shut down by license condition (iii) without the plant being shut down by CP&L rule or procedure (iv) without being known to plant l operators in normal operation (v) allowed in normal operation?

ANSWER. The percentage of fuel cladding defect which l

l l

l corresponds to the primary coolant concentration limit of'1.0 microcurie per gram dose equivalent I-131 is approximately 0.23%. There is no TS limit on the fuel cladding defect fraction. Rather, limited conditions for operation are placed on the actual coolant concentration. During normal operation there is no instantaneous way to determine the cladding defect fraction. However, an evaluation of this value can be made following a determination of the fission product coolant concentration and correlating it to previously known values of coolant concentration and fuel defects, which will be specified in plant procedures.

INTERROGATORY NO. 29-4(o). Please give responses to all parts of (e) through (n) above with respect to Applicants Robinson 2 plant instead of Harris, i.e. answer all such parts with the words " Robinson 2" replacing " Harris" wherever the word " Harris" occurs therein.

OBJECTION. Applicants object to the provision of the

, requested information concerning the Robinson 2 plant. The design characteristics of SHNPP render any such information f irrelevant due to the dissimilar plant design of Robinson 2.

l Whatever information Applicants possess regarding the Robinson 2 plant was not utilized in calculating radioactive releases or l

appendix I compliance at SENPP. See Applicants' response to Interrogatory 29-1(p). Consequently, such information is irrelevant, will not lead to the discovery of any relevant

- information, and is objectionable.

l

= - . - - . _

1 INTERROGATORY NO. 29-5(a). For each filter, trap or other component at Harris.(or in the Harris design) which Applicants intend or expect.to remove radioiodines from the effluents of the plant, please state the following: (i) the maximum amount of each radiciodine isotope such component can absorb or remove from effluents, stating from which effluents radioiodine is to be removed; (ii) the maximum amount of all radiciodines

.together which such component can remove from each effluent (e.g. water, air); (iii) the exact effect of humidity on such ,

component's ability to absorb, trap or remove radioiodines from effluents; (iv) if the effect described in response to (iii) i above is different for any radioiodine isotopes, please state all such differences for each isotope compared to (aa) I-129 ,

.and (bb) to I-131; (v) a list of all conditions known.to

, Applicants which can or will render such component inoperable; (vi) a list of all conditions known to Applicants which can or will prevent such component from removing radio-iodines (aa) at its full rated ability; (bb) at any level above 75%-of its full ,

rated ability; (cc) at any level above 50% of its full rated ability; (dd) at any level above 25% of its full rated ability (ee) at any level above 10% of its full rated ability; (ff) at ,

any level above 5% of its full rated ability; (gg) at any level above 1% of its full rated ability. Full rated-ability means

its normal ability (in amount, or in %, of radiciodines passing such. component or input into it or past-it) to remove radicio- ,

dines. (vii) If any of the responses to any parts of (v) or

. (vi) above or to (v) above or (vi) above entire, would vary with radioiodine isotope involved, please state all such variations (i) as compared to I-129;.(ii) as compared to I-131.

(viii) If Applicants do not have the above-requested informa-tion for any specific radioiodine isotope, or all radioiso-topes, of iodine, please state all information Applicants do have, responsive to any part of (a) above, for any or all radioiodines, identifying the interrogatory to which each such answer is responsive.

ANSWER. Applicants do not have the detailed information requested in 29-5(a) nor is it required by NRC that Applicants have this information. However, more generally, ths filters 4

and other processing equipment used in the SHNPP gaseous and liquid radioactive waste systems to remove or absorb radioio-dines and other nuclides have been designed and constructed

, following industry standards and auidance from the NRC as given

, -F7-

in various regulatory guides. Compliance with these standards and guides in the design, manufacturing, testing and operation of the radioactivity removal systems will ensure their adequate performance.

INTERROGATORY No.-29-6(a). Are all maintenance and technical specifications and procedures, and design data, related to radiciodine filters, traps, absorption or removal devices, and monitoring at Harris given in the FSAR and the ER?

ANSWER. No.

INTERROGATORY NO. 29-6(b). If response to (a) is other ~

than affirmative, please identify all documents which contain such information, detailing for each the information it contains which is inquired about in (a)~above.

ANSWER. The FSAR (including Technical Specifications),

purchase order specifications and vendor equipment manuals.

INTERROGATORY NO. 29-6(c). If response to (a) above is affirmative, please identify the sections of the FSAR, and of the ER, in which such information is contained, stating what information is contained in each (e.g. FSAR X.Y.1.3.1 contains the description of all radioiodine traps and their design).

ANSWER. Not applicable.

1 INTERROGATORY NO. 29-6(d). If response to (a) above is other than affirmative, please provide the information reques-ted in (c) above for all data requested in (a) above which is in the FSAR or the ER.

ANSWER. This information is scattered throughout the

FSAR. Examples include Sections 9.4 (HVAC Systems), 11.5 (Monitoring and Sampling Systems), 12.3 (Radiation Monitoring),

and 16.2 (Technical Specifications).

INTERROGATORY NO. 29-6(e). Identify any other information relating to radioiodines which is in the FSAR or ER and was not requested above, stating where such information is located, in the FSAR or ER. (e.g. FSAR Y.X.1.1.1 has the radioiodine source term, and Y.X.1.1.1.3(b) has the derivation of that source term, for all radioiodine isotopes).

ANSWER. Ncne.

INTERROGATORY NO. 29-6(f). Please describe all mounting or sealing gasketc, frames, and devices to be used 11 connec-tion with (i) radiciodine-absorbing filters (ii) other devices used to remove or trap gaseous or liquid radiciodines (or i radioiodine particulates) from effluent stresms (air or liquies or other material moving toward or to a discharge point, .

airectly or indirectly) at Esrris, giving the following information for each: (iii) the :aaterial and manufacturer, (iv) the dimensions (v) the mounting or attachment of r,uch gasket, frame of device, (vi) what it is mounted on, or in, or

attached to (vii) if it is not attached pisase describe how it is kept in-place, what it resta on, and how it may be removed; (vii) what parts of it are in contact with effluents, giving dimensions and describing which parts are in contact, if any; if none, so state; (viii) whether Applicants have determined the (aa) maximum, (bb) typical or average, (cc) minimum radiation exposure to which such mounting, or sealiig gasket, frame or device will be exposed in normal Harris operation; (ix) whether Applicants have determined or know the (aa) maximum (bb) normal or average, (cc) minimum concentration of

( (xx) oxygen (yy) nitrogen (zz) water, (ww) particulates to I which such device will be or is expected to be exposed in normal Harris operation; (x) For each such device being described in respense to this interrogatory (f) and its parts aob above, please give each determination which Applicants have made or know, which was inquired about in (ix) above. (xi)

Have Applicants done any study of embrittlement of gaskets or l seals in the Harris plant due to exposure to (aa) radiation (bb) oxygen (cc) both radiation and oxygen (dd) radiation at doses below or equal to those stated for any component or device in response to (x) above? (xii) If answer to any part of (xi) above is affirmative for any device, or component, then for each such device or' component please. identify (aa) all documents concerning the study or containing the results, or methods, or records of such study; (bb) the authors of each such document identified in response to (aa) above; (cc) the qualifications of each such author; (dd) all instruments or equipment used in such study; (ee)_which documents contain the ,

results of the study; (ff) what uncertainty was determined to be in those results. (xiii) What the design life af such component, device, gasket or sealing device is; (xiv) what schedule such component, device, gasket, or sealing device will be replaced on, according to Applicants' current plans; (xv) the radiation exposure to personnel involved in such replacement, per device, if Applicants have made a determina-tion or estimate of1such exposure; (xvi) the internal and external radiation in any determination or estimate given in response to (xv) above, including which radionuclides, if any,

! are expected to be deposited internally in any person replacing such device. (xvii) the failure rate of such seal, gasket, or

-mounting or sealing device estimated by Applicants; if no estimate made, so state; if actual data used to give failure rate, identify source of data and all documents containing such ,

3 data; (xviii) identify all documents containing actual or estimated failure rate of such component, or estimated lifetime

, of such component without failure. " Failure" means failing to l perform its function, e.g. leaking for gaskets, seals and

} sealing devices.

PARTIAL ANSWER / OBJECTION.

i (i) Air Cleaning Units Charcoal Absorbers The charcoal absorbers on the Air Cleaning Units are all welded, gasketless, hopper type construction using 304 stainless steel. These units are welded to the casings and become integral part of the units. Consequently, the rest of i

the information asked for in this interrogatory is not appli-cable. -

i

4 Volume Reduction System Filter-Assembly L

The. exhaust gas filter assembly of the Volume Reduction l System consista of a charcoal bed with HEPA filters upstream and downstream of the bed. The filter housings are fabricated' of carbon-steel and are of'an airtight welded construction.

The housings are mounted on a six inch channel base to prevent a t corrosion and allow for foundation bolting. Each HEPA and

, charcoal absorber has its own sealing gasket securely cemented i

to the filter' frame. The seal'is provided by compressing the filter gasket against the seal plate opening in the housing.

For gasket material, see Applicant's response to Interrogatory ,

29-1(n).

(ii) All components and piping systems,for the liquid and gaseous radioactive waste processing systems are designed in accordance with the guidance set forth in P.egulatory Guide-1.143 entitled " Design Guidance for Radioactive Waste Manage-ment Systems, Structures, and Components Installed in Light-l l - Water-Cooled Nuclear Power Plants." For example, all radwaste l-components / systems are of welded construction except where ,

other-types of connections, such as flanges, are necessary for 1

maintenance. Welded construction does.not require special seals or sealing materials and will minimize the potential for leakage from the radwaste systems. Another example is the.

i basis for component material selection. Regulatory Guide 1.143 l .has specific guidance which stipulates that the materials l

l f.

, _,.-.--r.m.,y -.,_--.y-

p. ,.,,,.,-,,--,q.- ,,w .,,-..,,_w,,,.,nw,-,,,

identified in Section II of the ASME Boiler and Pressure Vessel Code except for malleable, wrought, or cast iron and plastic pipe are acceptable for use in radwaste systems. All radwaste system component materials of construction at the SHNPP were selected in accordance with these requirements. FSAR Tables 11.2.1-7 and 11.3.2-7 identifies the materials of construction for the main process components in the radwaste systems.

(iii) Materials are specified above and in response to Interrogatory 29-1(s).

(v) See Applicants' response to (i), above.

(vi) See Applicants' response to (i), above.

(vii) Not applicable.

(vii) [ SIC] The air handling and filtration units, piping and duct work all can be exposed to the effluent streams.

(viii) The Applicants have determined the maximum conservative integrated radiation dose for the components described in (1). This is presented in FSAR Appendix 3.llB.

(ix) Applicants have not determined the concentration of oxygen, nitrogen, or particulates to which these components will be exposed during normal operation; however, the Applicants have determined the components' exposure to appli-cable ambient conditions including humidity, as expressed in each component's specifications.

- , , . , , - , c -g . , , , - - - - , r - - - --

.-. . _ _. . _. .=

(x) The Applicants have reviewed historical data and system functional capability to determine the normal and abnormal range of environmental conditions postulated to occur at the ' apprcpriate equipment location (s) .

(xi) See. Applicants' response to Interrogatory 29-1(t).

'(xii) Not applicable.

(xvii) Applicants do not determine the failure rate of a component. This is determined by the vendor.

(xviii) See Applicants' response to (xvii), above. ,

OBJECTION. Applicants object to (iii) with respect to identifying component manufacturers, (iv) regarding component dimensions, (xiii) regarding design life, (xiv) regarding l replacement schedule, and (xv) and (xvi) regarding personnel exposures. None of these questions are relevant to Contention

..2 9 , concerning compliance with Appendix I.

INTERROGATORY NO. 29-7(a). What is the minimum configura-tion of radioiodine absorbing, trapping or filtering devices at Harris which is allowed during normal operation? Please list each component or device in this configuration, and the number of each required to be operable at all times during normal operation.

ANSWER. There is no minimum configuration of radioiodine absorbing, trapping, or filtering devices at the Harris Plant.

The gaseous radwaste treatment system is designed to operate on I

a w ..,,-9 -

the-basis of projected doses'to the public. This system is described in Sections 9.4 and 11.3 of the FSAR. The operabi-lity of the gaseous radwaste treatment system and the ventila-tion exhaust treatment system ensures that the systems will be available for use whenever gaseous effluents require treatment prior to release to the environment. The requirement that the appropriate portions of these systems be used, when specified, provides reasonable assurance that the releases of radiciodine in gaseous effluents will meet the requirements of 10 C.F.R. 50, Section 50.36a, general design criterion 60 of Appendix A to 10 C.F.R. 50, and the design objectives given in Section ,

II.D of Appendix I to 10 C.F.R. 50. The specified limits governing the use of appropriate portions of the systems are specified as a suitable fraction of the dose design objectives set forth in Sections II.B. and II.C. of Appendix I to 10 C.F.R. Part 50 for gaseous effluents. Assuring compliance with i

these requirements is more appropriate than defining a number which must be operable at all times.

INTERROGATORY NO. 29-7(b). On what schedule is the operability of each component listed in response to (a) above to be verified, and by whom. (Please state for each such component, including all devices and components identified in response to (a) above).

ANSWER. Because there is no minimum configuration of radioiodine absorbing, trapping or filtering devices, see Applicants' response to Interrogatory 29-7(a), this interrogatory is not applicable.

l

_ _ _ _.- _ = . . _ . . . , __

INTERROGATORY NO. 29-7(c). Who is responsible for each such-' verification?-

ANSWER. See Applicants' response to Interrogatory 29-7(a) above.

INTERROGATORY NO. 29-7(d). Must the plant (Harris) be shut down if such verification is not made?

ANSWER. See Applicants' response to Interrogatory 29-7(a) above.

INTERROGATORY NO. 29-7(e). Please list all such veri- ,

fications which, if not made, will (1) cause the plant to be shut down; (ii) cause the plant to be derated, giving the derating required, (iii) require the plant to be shut down; (iv) require the plant to be derated, giving the derating required.

ANSWER. See Applicants' response to Interrogatory 29-7(a) above.

INTERROGATORY NO. 29-7(f). Please give the schedule on which each component identified in response to (a) above is to be replaced at Harris.

ANSWER. See Applicants' response to Interrogatory 29-7(a) above.

INTERROGATORY NO. 29-7(g). Please give the schedule on which each component identified in response to (a) above will be serviced, stating all actiors to be taken and all checks to be made in servicing same. " Schedule" as used herein means any times (e.g. 3 times per year, during each refueling outage, before every plant startup from cold shutdown, etc., as well as any schedule giving exact dates or approximate dates.

ANSWER.- See Applicants! response-to Interrogatory 29-7(a) above.

. INTERROGATORY NO. 29-8(a). Please identify all materials used in (i) radioiodine-trapping filters for use at Harris (ii) mountingstof such filters (iii) gaskets or seals for such

, filters (iv) maintaining airtight conditions in air or gas

. pathways at Harris where Applicants expect that radioiodines may or will be present. ,

i INTERROGATORY NO. 29-8(b). Please state which of the above materials incorporate (i) polyethylene, (ii) polyvinylchloride (PVC)-(iii) chloroprene (iv) ethylene propylene rubber (v) neoprene (vi) crosslinked polyolefin materials (vii) chlorosulfonated polyethylene (viii) any other rubber (ix)-any other polymer (x) any flammable material, including any of the preceding.- ,

, INTERROGATORY NO. 29-8(c). Please' state whether Applicants have determined (i) the tensile strength, (ii) the change in tensile strength when exposed to radiation and oxygen, (iii) the swelling when exposed to radiation and lower oxygen levels than 21% (iv) the change in tensile strength when i exposed to radiation and then to heat (v) the swelling when

exposed to radiation, heat, and oxygen levels below 21% (vi) l the tendency to crack (vii) the speed of oxidation at the

! temperatures such material is expected to be at Harris, for each material identified in response to (a) above.

ANSWER. See Applicants' answers to Interrogatories 29-1(s), 29-1(t) and 29-6(f).

INTERROGATORY NO. 29-8(d). Please state whether Applicants have analyzed the effect of fires at Harris on the oxygen concentrations to which each of the materials identified in response to (a) above are exposed.

INTERROGATORY NO. 29-8(e). For each material for which your response to (d) is other than affirmative, please state any information in possession of Applicants, not already identified in response to other interrogatories, which gives for that material any of the properties (or characteristics, if t

4 you will) listed:as-(i) through (vii).under-(c).above, including the identification ofiesch' document containing information, which of the things listed as (i) through (vii) of (c) above'it contains, on what page, who wrote it, and when.

1

-INTERROGATORY NO. 29-8(f). For each material for which your response.to (d) above is affirmative, please state whether Applicants have any of the information about the properties (i) '

through (vii) of (c) above.

INTERROGATORY NO. 29-8(g). Identify.which information, and all documents.containing that information, Applicants possess, for each affirmative response to (e) above for each material.

OBJECTION. Applicant objects to the provision of l information under 29-8(d)-(g). The requested information is i

completely irrelevant to the estimation of radioiodine releases and Appendix I compliance at SHNPP.

RESPONSES TO INTERROGATORIES r ON CONTENTION 37B i

j. INTERROGATORY NO.'37B-1(a). Please identify or list all i diseases which Applicants have estimated the increased inci-dance of due to operation.of the Harris plant, including those which have been specifically calculated for increased incidence for which Applicants have calculated there will be no increase.

ANSWER. None.

INTERROGATORY NO. 37B-1(b). Identify, for each such disease, (i) all documents wherein such estimate of calculation was made, (ii) all documents and information relied upon by Applicants in making such calculation or estimate, (iii) who made the calculation and state when such calculation or estimate was made, and who made the estimate (if not already stated), (iv) any estimate known to Applicants for (aa) the -

increased incidence of such disease due to Harris operation (bb) the value of any number, factor or relationship used in t

m making Applicants' calculation of estimate, (cc) any other information relative to the increased incidence of such disease due to external or internal radiation or radionuclides, which (for (aa) through (cc) or any of them) is higher than the Applicants' calculation, estimate, or any number, factor or relationship used in making such calculation or estimate, of which would increase Applicants' estimate if it were used in l making such calculation or estimate.  ;

i ANSWER. Not applicable.

INTERROGATORY NO. 37B-1(c). Please identify all informa-tion in the possession of Applicants which alleges or states that (aa) NRC (bb) BEIR-III or the BEIR Committee (cc) i Applicants (dd) EPA (ee) NRC models (ff) Applicants' models or l calculations; (gg) underestimate radiation exposure to (1) human beings or a human being; (ii) animals (iii) food crops ,

(iv) air (v) water, within 50 miles of Harris, or in connection I with operation of any other nuclear power plant, (hh) underes-timate the incidence of any disease due to expcsure to radia- l tion or any radioactive material listed'in 10 CFR 20 and its appendices.

INTERROGATORY NO. 37B-1(d). Please list all diseases for which any information was identified under (c)(hh) above.

OBJECTION. Applicants object to Interrogatories 37B-1(c)

! and (d), which are overly broad. Moreover, such information I

can be researched as readily by Mr. Eddleman as it can be by Applicants. See Pennsylvania Power & Light Company (Susquehanna Steam Electric Station, Units 1 and 2), 12 N.R.C.

317, 334 (1980).

i INTERROGATORY NO. 37B-2(a). For each document identified thus far by Wells Eddleman in response to Applicants interroga-tories concerning Eddleman contention 37 B, please state (i) l whether Applicants possessed a copy of such document before Eddleman made same available tc them (or, for documents not l made available by Eddleman, whether Applicants possessed a copy of same before Eddleman's responses to interrogatories, in

4 which'he. identifies such document, were received by

- Applicants); (ii) whether-Applicants have made any analysis or study of such document; (iii) for all affirmative responses to (ii), and each of them, who made the study, when, who ordered the study (if anyone), the results of such study, the identity

, of all documents containing the results of-such study, and .

4

- whether Applicants intend to offer such study into evidence, in this proceeding (iv) for all responses to (ii) above which are other than affirmative, whether Applicants possess any study, response, critique, or analysis of such document made by anyone else other than Applicants; (v) for all affirmative responses

! - to (iv); please state the information requested for affirmative i response to (ii) in (iii) above; e.g. who made this study, response, critique, or analysis, when, etc., including whether Applicants plan to offer such study, response, critique or analysis into evidence'in this proceeding.

OBJECTION. Applicants object to the information solicited as being irrelevant and encompassing material prepared in ,

anticipation of a hearing. Furthermore, this material is protected under the provisions of 10 C'F.R. .

5 2.740(b)(2).

The question of when the documents provided by Mr.

Eddleman came to the attention of Applicants is irrelevant to the issue of radioiodine release estimation and Appendix I compliance. The tracing of Applicants' receipt of the docu-ments has no bearing on the accuracy of Applicants' compliance which must be shown prior to power operations. To the extent Mr. Eddleman seeks work undertaken by Applicants in. order to prepare to meet Contention 37B in this operating license proceeding, such materials are protected fron discovery. See J- 10 C.F.R. l'2.740(b)(2).

INTERROGATORY NO. 37B-3(a). Please list all diseases and other health effects (including deaths) which Applicants, in their ER,'have considered or mentioned.

69-

- - ~

-,p m. ~ w m-w--> -,-m w.,,,,n,--,, .,-w.-,,,,,,,,am,T- ,.,-------nvm,,- ,r-n,-ma,w,,-,- ,m,--vv- ,,e- -an,ma_-,----,--,---,-,,--o-en-,--.

INTERROGATORY NO. 37B-3(b). Please state which, if any'of the diseases and health effects identified in response to (a) above Applicants believe can be caused by (i) radiation (ii) radioactive material emitted from the Harris plant.

~ INTERROGATORY No. 37B-3(c). Please state if Applicants considered radioiodine doses to fetuses in their ER.

INTERROGATORY NO. 37B-3(d). If response to (c) is affirmative, please state at what page(s) such doses were considered.

INTERROGATORY NO. 37B-3(e). Please list all diseases Applicants believe can be (i) caused by radiation, (ii) contributed to by exposure.to radiation (iii) contributed to by exposure to low-level radiation (iv) caused by exposure to low-level radiation (v) made more severe by exposure to low-level radiation (vi) made more severe by exposure to

• radiation.

PARTIAL ANSWER / OBJECTION. It is unreasonably burdensome for Applicants to identify all specific diseases linked in any way by the medical and scientific community to radiation.

Moreover, producing such a list would require Applicants to conduct research which Mr. Eddleman could conduct. See Pennsylvania Power & Light Company (Susquehanna Steam Electric Station, Units 1 and 2), 12 N.R.C. 317, 334 (1980). Such a request is overly broad. See Boston Edison Company (Pilgrim Nuclear Generating Station, Unit 2), LBP-75-30, 1 N.R.C. 579, 581-85 (1975). However, in general terms the effects (dis-l eases) caused, or enhanced by radiation can be divided into two classes: (1) non-stochastic and (2) stochastic.

l i

1

Non-stochastic effects have-the following characteristics:

(a) a threshold dose, below which the effect does not occur at all, (b) the magnitude of the effect increases with the magnitude of the dose above the threshold, (c) with minor variations, all individuals exposed to a given dose come down with the effect, and (d) the effects occur within weeks or, at most, a year to two after the exposu're (the larger the expo-sure, the shorter the interval between the exposure and the appearance of the effect). Radiation-induced cataracts are an example of a non-stochastic effect.

Stochastic effects have the following characteristics:

(a) there is apparently no threshold dose, i.e., it is gen-erally believed that stochastic effects may occur at any dose, no matter how small, (b) the magnitude of the effect bears no

, relation to the dose, (c) the probability that an effect will appear increases with dose, (d) the effects occur many years after the exposure. The two-(and there are only two) stochas-tic effects of radiation are (1) the increased incidence of cancer, and (2) the increased incidence of hereditary damage.

At the dose levels to which employees and neighbors of the Harris Plant will be exposed, no non-stochastic effects will occur. Only stochastic effects can arise at these dose levels, and the probability that such effects will arise is extremely .

small.

I INTERROGATORY NO. 37B-3(f). For each-disease listed in i response to (e) above for which Applicants have not made an analysis of the increased incidence of such diseare to be expected due to the operation of the Harris units, please state all reasons, facts, and opinions held by Applicants to support

their not having made such analysis in the ER.

ANSWER. An applicant for an operating license is required to show that the operation of the proposed plant will conform ,

to the radiation limits set forth in the regulations of the Nuclear Regulatory Commissicn (10 C.F.R. 20 and 10 C.F.R. 50, l

- Appendix I). These regulations are based on the recom- l l

mandations of national and international bodies and take into I account the available knowledge on the anticipated incidence of stochastic effects. Consequently, it is unnecessary for an applicant to independently analyze the incidence of disease which the operatio'n of the plant may cause.

J INTERROGATORY NO. 37B-3(g). Please list all genetic defects and genetic diseases which Applicants believe CANNOT be caused by exposure to radiation in (i) one parent (ii) both parents (iii) any ancestor.

OBJECTION. If a genetic defect or disease cannot be l caused by exposure to radiation, it is outside the scope of Contention 37B. Furthermore, producing such a list would be l extremely burdensome and would require Applicants to conduct research which Mr. Eddleman could conduct. See Susquehanna, supra, 12 N.R.C. at 334.

t INTERROGATORY NO. 37B-3(h). Please list or define all diseases which Applicants believe CANNOT be caused by radiation.

. ...- . _ . , . - - - .. - . - . - - ~. - .-- - . - - . - . . - . . - ._ - ,- .

OBJECTION. If'a disease cannot be-caused by radiation,.it' 1

is outside the scope of Contention 37B. Furthermore, producing such a list would-be extremely burdensome and would require.

Applicants to conduct research which Mr. Eddleman could conduct. See Susquehanna, supra, 12 N.R.C. at 334.

l INTERROGATORY NO. 37B-3(j). Please list or define any disease not heretofore identified which Applicants believe can be caused by radiation.

ANSWER. The effects (diseases) caused or enhanced by radiation are described in Applicant's response to Interrogatory 37B-3(e).

i 4

. INTERROGATORY NO. 37B-3(k). For each disease listed or defined in response to (g) .or (h) above (or both), please state

'the basis of Applicants' belief that such disease CANNOT be

' caused by. radiation,- including all documents, experts, and information relied upon by Applicants in forming, supporting, holding or maintaining that belief.

l l OBJECTION. In. view of the irrelevancy of Interrogatories ,

37B-3(g) and-(h), Interrogatory 37B-3(k) is also beyond the '

l scope of Contention 37B.

INTERROGATORY NO. 37B-4(a). For each disease which  ;

Applicants have above stated can be caused by radiation, in

~

response to any interrogatory above, please' state whether

' Applicants believe (i) that such disease can occur among persons within 50 miles of the Harris site (ii) that the victims of such disease undergo pain and/or suffering (iii) that if anyone dies of such disease, that person will have undergone pain and/or suffering (iv) that if anyone lives with this disease chronically active, that such person will undergo -

pain and/or suffering (v) that if anyone lives with this -

disease active, that person may have expenses related to (aa)

treatment of=the-disease-(bb) pain relief (cc) maintenance of one's person due to incapacitation caused.by the disease.

ANSWER. The radiaticn standards, referred to earlier, specifically those in 10 C.F.R. 50, Appendix I, guarantee that the incidence of cancer and of hereditary damage caused by operation of: the Harris . facility will be so low as to be impossible to detect by the~most sophisticated epidemiological studie s .- Althouqh one cannot say that the operation of the Harris plant will not produce such effects among the people who

live within 50 miles of the plant, one can say with confidence that any such effects from operation of the Harris plant are ,

too improbable to be of any significance to health or general well-being. To the extent an individual may suffer from a form ,

of cancer or a hereditary disease, from whatever cause, the individual of course can undergo pain and suffering, can incur expenses from the disease, and can die from the disease.

i INTERROGATORY NO. 37B-4(b). Please list.all forms of

- mental retardation which Applicants believe CANNOT be caused by

. radiation, or define all such forms of retardation.

ANSWER. The Applicants are not aware that any form of i

mental' retardation has been observed to be caused by exposure of an individual to radiation.

• INTERROGATORY NO. 37B-4(c). Please state the basis for Applicants' belief that each such disease identified in

. response to (b) above cannot be caused by radiation.

i

- ,--r- + ,. -* - . _ , . . . -- ..e,. .- -.--,,,.-.-.y-e ,. e-, ..e-+,..w -,,.r- y y -- - , .

c ANSWER. Committee on the Biological Effects of-Ionizing Radiations, The Effects on Populations of Exposure to Low Levels of Ionizing Radiation: 1980, National Academy Press, Washington, D.C. ,-1980 (the BEIR-III Report); and, United Nations Scientific Committee on the Effects of Atomic Radiation, Ionizing Radiation: Sources and Biological Effects, l'982 Report to the General Assembly, United Nations, New York, 1982, (the UNSCEAR 1982 Report).

INTERROGATORY NO. 37B-4(d). Please list any forms of mental retardation Applicants believe CAN be cauced by radia-tion. .

ANSWER. See Applicants' response to Interrogatory 37B-4(b).

INTERROGATORY NO. 37B-4(e). Please provide the informa-tion requested in (a) above ("please state whether Applicants believe (i) . . . . disease.") for each form of mental retardation identified in response to (d) above.

ANSWER. Not applicable.

Objections submitted by:

&& 0. h_^^ ^ % -. _

Thomas A. Baxter, P.C.

Deborah B. Bauser Jeffrey J. A. Gibbs SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1090

Richard E. Jones Samanatha Francis Flynn CAROLINA POWER & LIGHT COMPANY P. O.. Box 1551 Raleigh, North Carolina 27602 (919) 836-6517 Counsel for Applicants Dated: June 17, 1983 1

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' SENSOR: S/N 201 -

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.f % mph range. The typical card has a positive 15mv

~e~.zero offset output,

pftenth moh. .

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METEOROLOGY RESEARCHs INC.

Wind SP eed .01 oz. in. '

, . f .,

Wind Direction . 3 oz. in..

g , }$ .q.

Quality / A s- sdra ncy hnician

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y4 / gA; r -

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' John L. Fenton Manager, quali:y Assurance

'True air speeds listed were producert in the P.RI Uinc T. r.r.el uho ,e 4: curacies are traceable to tr.e ::.tional Scroau cf Standards.

S calibration Specifications surpass applicable paragrapns et NRC Regulatory Guide 1.23.

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wm l r$7 PERTORMANCE REPORT w m wm TOR: .

CAROLINA POWER AND LIGHT

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SENSOR: 1074-22 ~ WIND SENSOR S/N 357 .-

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DATE: 12-2-76 4 y;Q

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' S,0. NO.

971 636 1360 REPAIR ED .s

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,;dp;.e NOTE: The following sensor speeds uere derived by conver-

d ting voltage outputs to mph from an t'RI Tacheteter Card set at a hz eaualing 5.00 VDC over a 9 to <

1 100 mph range. The typical card has a positive liev' 'Z

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.' 1 tenth mph. . -

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14.9 J'l , U.

[ 20.0 =

19.8 Iil  ;

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W.

30.0 =

29.5 li A L, '

!!ETEOR01.0GY RESEARCli, INC.

Wind Speed . 01 oz. in.

Wind Direction . 4 oz. in. - M 4

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Quality j4ssywance "I9epnicia.. ,

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,s j John'L. Fenten 11anager, Quality Assurance (N ~

• ~rse eir soeeds listed were produced in tho :e;I t.'ir.d Tur.nel whosc

• l cccuracies'are traceabic to tr.e lf4tional Barc.u. .,f Stand 4rds.

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PERFORMANCE REPORT w*

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FOR: Carolina Power & Light SENSOR: 1074-22 Wind Sensor S/N 354 DATE: December 9,1977 S.O. NO.t 971 637 3576 After Repair NOTE: The following sensor speeds were derived by converting voltage outputs to mph from a standard MRI Tachometer Card. The typical card has a positive 15mv zero offset output.

Readouts are to the nearest one tenth mph.

True Air Sensor Speed (NES)* Readout

.5 mph = Threshold

_ l.0 = 1. 0 mph 2.0 = 2. 0 3.0 =

2. 8 4.0 =

=

4. 0 5.0

5. 0 10.0 = 10.0 15.0 = 15.0 20.0 = 20.0 25.0 = 25.0 Wind Speed: . 01 oz. in.

Wind Direction: . 375 oz. in.

METIOROLOGY RESEARCH, INC.

A Qua_it-h $' surance Technician E-

,. t . -

A O John L. Fenton Manager, Quality Assurance s

• True air speeds listed were producad in the F.R Wind Tunnel wh:sc accuracies are traceabic to the :::.tional Sureau mf 5;&ndards.

O Calibration Specifica:icns sur,. ass applicable pcragraphs of NRC 2egulatory Guide 1.23.

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Box 637,464 West Woodbury Road 1 Altadena,CaMomia 91001 C' Telephore (213) 791 1901 Talex 675421 A Subsdaryof Cohu. Inc.

Elll*3^

PERFORMANCE REPORT .

t.

FOR:- Carolina Power & Light SENSOR: 1074-22 -Wind Sensor S/N 209

1) ATE: December 6,1978 l S.O. NO.t 971 638 5490 After Repair NOTE: Sensor readouts are obtained by converting the pulse p'er second obtained from a LED chopper assembly attached to the anemometer cup shaft.

True Air . Sensor Speed (NES)* Readout

.7 mph = Threshold C 1.0 = 1. 2 mph

2. 0  :

1.9 -

2. 9  :

3. 0

3. 7  :

3. 7 i

4. 5  : 4. 6 i

9. 5 . = 9. 6

14. 5 = 14. 7 l 19.7 19. 9 24.7 = 25.1 28.3 28.8 Wind Speed- .012 oz, in. METEOROLOGY RESEARCH, INC.

! Wind Direction- . 3 0 o z. in.

l Quality Assura cl, 67c ennici 4/n

[ .~

John L. Fenton Manager, Quality Assurance k- *True air speeds listed were producert in the .".RI Wind Tunnel whose accuracies are traceable to the Nr.tional Sureau o' Standards.

bCalibrationSpecificationssurpassapplicableparagraphsof NRC 'tegulatory Guide 1.03.

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Box 637,464 % 2st Woodbury Road I:*

' ---d Altadena.Colornia 91001 . .

Teleonone (213) 791 1901 Telen 675421 [ lit B*l A Subsdaryof Cthu.Inc.

C PFRFORM1.*!CE REP 0n?

' C. clina Power & Light TOR:

SENSOR: 1074-22 Wind Sensar S/N 357 DATE: ' April 19, .1979 S.O. NO.t 971 639 6188 After Repair ,

NOTE: Sensor readouts are obtained by converting the pulse pe,r second obtained from a LED chopper assembly :tttached to the anemometer cup shaft.

True Air Sensor

• Speed (NBS)* -

Readout,

, 4. 6 mph = Threshgld

.9  : .1.O mph C 1.9 = 2. 0 -

2. 9  : 2. 9

3. 9  : 3. 9

4. 5

4. 4

9. 4

9. 5

14. 7 14.5 -

18. 8 18. 6 24.0 23.6 27.8 27.6 ._

Wind Speed: . 004 oz. in. METEOROLOGY RESEARCH, INC.

Wind Direction: . 25 oz. in. g h& W Qualit" .ssurarce' 4 chnfcian

,Q / ~

John L. Tenton Manager, Quality Assurance

• True air speeds listed . sere pmducert in tr.e .".R Wine ;unnel whose

( accuracies are traceable to tr.e ::t.tional Screau sf Standards.

• G Calibration Specifica: ions surpass a;;11cstle paragr.sphs of NRC 2egulatory Guide 1.23.

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f Bon 637. 404 West Wc'odbery Road -

Attadena. Cahlornia C1001 .

Telechone (2131791 1901 Teles 675421 Illl'1 A Sabs6ary at Cohu. Inc.

PERFORMANCE REPORT (After Repair)

FOR: Carolina P&L SENSOR: 1074-22 S/N 364 DATE: 11 October 1979 ,

S.O. No: 971 639 6983 NOTE: Sensor readouts are obtained by converting the pulse per second obtained from a LED chopper assembly attached to the anemometer cup shaft.

True Air Speed Sensor (NBS)* Readout

.6 mph = Threshold

.7 mph = .7 mph

1. 6 mph 1. 6 mph

2. 4 mph = ,2. 5 mph l

( ,

3. 4

3. 7 mph mph

=

3. 4

3. [

mph mph

8. 9 mph =

9.1 mph

. 13.9 mph = 13.4 mph 18.O mph = 18,2 mph 23.O mph = 23.I mph 26.3 mph = 26.5 mph W/S Shaft .004 n YW ualid.GcZA.///,. A ssuranc Technician W/D Shaft .35 ,/ .-

u -% w/ .

John L. Fenton ,-

Manager, Quality As surance -

~

1

~

ie -

'True air speeds listed were produced in the MRI Wind Tunnel whose accuracies are traceable to the National Bureau of Star.dards.

Calibration Specifications surpass applicable pacar,raphs of NRC

] Regulatory Ctide 1.23.

I

2 .- ..

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- ~. Meteorology Research, lac. y '~

Box 637,464 West Wooccury Road [.

Altadena. Calif ornia 91001 ! .

Telephone (213) 791 1901 Telen 675421 <llll*l A Subsdary of Conu. Inc.

PERFORMANCE REPORT FOR: Carolina Power and Light SENSOR: 1024-. W-in ensor SN: 897 DATE: h_ch 26,1980 S.O. No: 9716307615 ,

NOTE: Sensor readcuts are obtained by converting the pulse per second obtained from a LED chopper assembly' attached to the anemometer cup shaft.

True Air Speed Sensor (NBS)* Readout

.3 mph = Threshold

.7 = .8 mph 1.6 . = 1.6 2.4 = 2.7 3.3 , 3.3 .

3.7 = 4.0 .

~

8.1 = 8.8 12.9 = 13.8 16.7 = 17.7 21.3 = 22.5 24.5 = 26 Ouality Assurance Technician 4%tw& tit / Itch y 6 L .

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W/S Shaft 0.01 '

W/D Shaft 0.45

• True air speeds listed were produced in the MRI Wind Tu=nel whose accuracies are trae:eable to the National Bureau of Standards.

Calibration Specifications surp. ass applicable paragraphe of NRC

. , Regulatory Guide 1.23.

s V,b Rev. 10/74 w7 1

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Meteorology Aer,carch.Inc.

tice t ' *. 4G4 v.. it W> *: ar ) An id -

Alta.9.a Ciao a 91001 ..

TWchone(213) 791 1901 T c a 6/5:21 till*l ,

A S meauy ,t t'.cnu. Inc.

PERFORMANCE REPORT CUSTOMER: Carolina Power & Light .

S ENSOR: 1074-22 S/N: 320

! N EW: Before Repair : After Repair: _x S. O. #: 9716308279 ,

DA TE: August i,1980 /

NOTE: Sensor readouts are obtained by converting the pulse per second obtained from a LED chopper as sembly attached to the anemo-

, meter cup shaft. ,

True Air -

Sensor Speed (NES)* R eadout

.5 mph Thr estfold ,

.8 = .3 C 1.8 ,

= 1. 6 2.8 = 2. 6

! 3.9 = 3. 7 5.0 = 4. 8 l 10.1 = 10.1 20.6 = 20.5 .

1 25.8 = 25.6 -

31.0 = 30. 8 35.7 = 35.3

=

M ET F'O,ROLOGY .R ESEARCH, INC.

,....,...,n' ~

Cuality Control Technician

.b' ( l . .

A. K. Wehl -

Supe rvi sor, Quality Cont rol {-

• True air speeds listed were produced in the MRI Wind Tunnel whose

~~

accuracies are traceable to the Na'.innal Bureau of Standards.

Calibration Specifications surpass .isplicable paragraphs of NRC ,

R egulatory Guide 1. 23.

{ ,

b

. ~

}

L-10

~

Meteorology Research,Inc.

Box 637.464 West Woechury Road Attacena, Cahu,rnia 91001 .

Teieonone (213) 791 1901 Telex 675421 llbl'8 A Subs #ary of conu. Inc.

PERFORMANCE REPORT c

CUSTOMER: Carolina Power & Light SENSOR: 1074-22 S/N: 896 New Before Repair After Repair x S. O. #: 9716319359 l

DATE: April 28,1981 NOTE: Sensor readouts are obtained by converting the pulse per second count obtained from a LED cliopper assembly attached to the anemometer cup shaft to wind speed using 7.64 feet per revolution (25.34 Hz/ mph).

True Air Sensor Speed (NBS)* Readout Dif ference (mph) _ (mph) (mph)

0. 68 0.40 -0.28

, 1. 23 1.05 -

- 0. 18

2. 15 2.04 -0.11 3.20 3. 13 -0.07 l 4. 18 4. 12 -0.06

! 5.39 5.43 0.05 10.86 11.03 0. 17 16.70 16.89 0. 18

, 22.30 22.60 0.30

) 27.06 26.97 -0.09 36.78 36.90 0. 12 l

METEOR 0 LOGY RESEARCH, INC.

/ -

sn-< s M ality C ntrol Technician

,- / -

~

ity As ance anager .

Accuracy of NBS Calibration = + 0.1 mph Date //- 2 fPC-- V/

• True air speeds listed were produced in the MRI Wind Tunnel + hose accuracies are traceable to the National Bureau of Standards.

Calibration Specifications surpass applicable paragraphs of NRC

• Regulatory Guide 1.23.

t 60

hNMNE#.hasssIdMSN5bTMEMMWD2h~"lGiiArJ l

) L 11 Meteorology Research, lac.

Box 637,464 West Woodbury Road A!!adena.Cahfornia 91001 .

Telephone (213) 791-1901 Telex 675421 Illt'l A Subsidiary of conu,Inc.

'u PERFORMANCE REPORT

i CUSTOMER

Carolina Power And Light Co.

i -

SENSOR: 1074-22 S/N: 898 i '

After Repair X

NEW Before Repair

^

. S. O. #: 9719910343 DATE: December 11, 1981 NOTE: Sensor readouts are obtained by converting the pulse per second count obtained from a LED chopper assembly attached to the anenometer cup shaft to wind speed using 7.64 feet per revol'ution (25.34 Hz/ mph).

3 True Air Sensor

• Speed (NBS)* Readout Difference (mph) (moh) (moh)

D _

Threshold 0.33 - 0. 31

j. 0.64 1.39 1.17 -0.22

,: -0.12 1 2.25 2.13 3.23 3.11 -0.12 l; -0.20 4.26 4.06 5.13 5.06 -0.07 9.89 9.83 -0.06 14.54 0.01 14.53 19.17 19.19 0.02 23.80 23.82 0.02 27.40 27.42 0.02 l

's a 1

METFAROLOGY RESEARCH, INC.

)L -

d gy 7

1. - QualityVControl Technician ,-

/ sn h uality Assurance Manager n

a Accuracy of NBS Calibration = 0.1 mph Date December 14, 1981 r

• True air speeds listed were produced in the l1RI Wind Tunnel whose i accuracies are traceable to the National Bureau of Standards.

) Calibration Specifications surpass applicable paragraphs of NRC Regulatory Guide 1.23. g i V

E . .

3 e

1 L-12

.# Meteorology Research,Inc. y  ;

Box 637,464 West WoocDury Road g

'( Altadena. California 91001 s .i Telephone (213) 791-1901 Tetex 675421 A Sucsdiary of Conu. Inc.

Itill'I ]

^

h.

PERFORMANCE REPORT CUSTOMER: Carolina Power and Light Co.

S/N: 325 SENSOR: 1074-22 Before Repair After Repair X NEW S. O. #: 9716320873 DATE: May 26,1982 '

NOTE:

Sensee readouts are obtained by converting the pulse per second count obtained from a LED chopper assembly attached to the anemometer cup shaft to wind speed using *7.64 feet per revolution (25.34 Hz/ mph).

True Air Sensor Readout Difference Speed (NBS)* (Moh)

(mph) (mph) 0.54 Threshold -0.13 0.96 0.83 1.83

-0.18 2.01 -0.13 3.13 3.00 .

3.95 -0.12 4.07 -0.14 5.10 4.96 10.18 -0.08 10.26 0.00 16.90 16.90 22.77 0.01 22.78 0.02 i

27.43 27.45 35.35 0.08 35.27 METEOROLOGY RESEARCH, INC. ,

f]j g />.,ns. >r

-paliy'ontrolTechnician Q ality Assurance \Hanager i Date May 26.1982 Accuracy of NBS Calibration = + 0.imph P

• True air speeds listed were produced in the MRI Wind Tunnel whose accuracies are traceable to the National Bureau of Standards.

ons suroass applicable paragraphs of NPC p

' c- - . _ _ 3*

=== * -

' k L-13 Meteorology Research,Inc. {' ~N(

• Box 637.4G4 West Wcoccury F.o:5 . --

Attacena.Cahtornia 91031 .

Telechone (213) 791 1931 Teles 675421 ""

Ill!*3 A Sucscary of Conu. Inc.

L PERFORMANCE REPORT l

CUSTOMER: Carolina power & Light Co.

SENSOR: 1074-22 S/N: 357 l

AS RECEIVED X AFTER REPAIR

! NE!!

S. O. i: 9716321331 DATE: October 13, 1952 NOTE: Sensor readouts are obtained by converting the pulse per second count obtained from a LED chopper assembly attached to the anemometer cup shaft to wind speed using 7.74 feet per revolution (25.00 HzMph).

True Air Senser Speed (NES)* Readout , Difference (mah. (moh) (moh) 0.57 Threshold .

1.03 0.81- -0.22 2.04 1.90 -0.14 3.12 2.98 -0.13 4.03 3.91 -0.12 5.02 4.96 -0.06 10.21 10.22 +0.01 16.74 16.85 +0.11 22.45 22.66 +0.21 26.84 27.05 +0.21 34.50 34.66 +0.16 i'ETEGROLOGY RESEARCH, INC.

i Quality Control~ Technician

/l ,;

G N .s.'Cy- -

Quality Assurande Manager .-

Date October 20, 1922 Accuracy of NES Calibration = + 0.1 rph

• True air speeds listed were croduced in the MRI 'Aind Tunnel wnose accuracies are traceable to the National Eureau of Sta.edards.

Calibration Specitications surpass applicable paragraphs of NRC Regulatory Guide I.23.

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Masi.ne aN:

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Cold 91006 E Phee 21319t 1918

. PERFORl!A!!CE REPORT True Wind Speeds Listed Were Derived in' the !!RI Wind Tunnel Whose Speeds Are Traceable.to the National Bureau of Standards-FOR: Carolina Power S Lir,ht SENSOR: 1074-22, S/l! 327 Refurbished .-

DATE: 15 October 1975 S.O.: 9716351223 NOTE: The followine, sensor speeds were derived usinc. a t standard !!RI Wind Speed Card Assy. 1290500 or 1282300, set for 2500 ilz. equalinr. 5.00 volts 100 mph full scale and with a positive #

14 mv zero offset output.

( .-

Tunnel mph (HBS)

Sensor Peadout moh 0.60 mph = Threnhold O.75 = 0.6 mph

, 1 = 0.9 2 = 1.9 3 = 3.0 4 = 88 . 0 5 = 5.0 10 = 10.0 15 = 15.0 METEOROLOGY PI'.GUARCll, ll!C .

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. Keith S tore ,- . .

Senior licctp ic 5 Enc ince r f . . .

L,fQuality

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flee A37 Altabas.

r.s m.

.: .w n,. m a nm 1 P E R T O Rf-!A tl C E R E P O R T I .s. .

j 3 True Wind Speeds. Listed Here Derived in the !!RT Wind Tunnel

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..s:

Whose Speeds Are Traceable to the National Bureau of Standards i., 3

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FOR: Carolina Power & Light

• h,f .. .' SEilSOR: 1074-22 S/II 320, Refurbished '

y-

. DATE: 26 September 1975 A

S.O.: 9716351175

.I'

,. NOTE: The following sensor speeds were derived using a standard 11RI Wind Speed Card Assy. 1290500 or T ,. -

+

1282300, set for 2500 liz. equaling 5.00 volts '

• • • 100 mph full scale and with a pesitive 14 mv zero offset output.

(~. Tunnel

~

Sensor mIi n Readout (flBS) mph l ,,d - True 0.05 mph =

0fp 3, True 0.75 mph =

Threshold l fy.(. 1 =

0.GG mph 0.96

'g fr2, 2 =

1.94 3y$:- 3 = 3.00

,)}. i. '.'. . 4 =

3.99 -

9, n. .'

5 =

5.02

~ $Y;fk' 10 =

10.0

'Dh  :

15 =

'.?rj 15.1

.,5 .

I-iETCOROLO'3Y Hl:SI:ARCil, l!!C.

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{ IIs t*I melcarningy research, Inc. 464 w.mondiniry nl. aliadena, ralif.

PERFORMANCE REPORT ""'"'"

w, - list 637. Ahaena.

c.u sion Phase: 213 791-1908 g FOR: Carolin'a Power ac Light Co.

SENSOR: 1074-22 Wind Sensor S/N 322

DATE

April 1,1977 I. S.O. NO.: 971 637 2307 Af te r -R epair NOTE: The following. sensor speeds were derived by conver-

, ting voltage outputs to mph from an MRI Tachometer Card set at 2500 Ec ecualins; 5.00 VDC over a 0 to 100 mph range. The typical card has a positive 15=v l

Il zero offset outtut. Readouts are re the nearest one

~

tenth.meh. --

ll -

, True Air Sensor .

Speed (NES)* Readout

.55 mph  : 2.reshold

,l .

.il f' l.0 = . 6 mph

,' (

2.0 =- t, 7 3.0 =

2. 8 4.0 =

3. 8 A

5.0 = 4. 7 10.0 = 9, 9

=

l]-

. ). 5 . 0 15.1 20.0 = 20.0 25.0 =

25.0 30.0 = . 29.9 e

f I

Wind Speed . 02 oz. in. METEOROLOGY RESEARCH, INC..

i Wind Direction . 25 oz. in. '

-f-

,%.s.3 $ /l ,9)/ T Quality Ass rance Technician

( l' -

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L-  %

Je.l an-//C*Fenten L.

( Manager, Ouality Assurance

^

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'True air speeds listed were p

educer*. in the :0,1 L'i .d Tu .nel whose ,k accuracies are traceabic to the :: .tional Sureau sf Standards. V

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@ .C411brati.cs

. , , . , . _ . .Specifi.ca:icas

......:., -- surpass applicable paragrap;.,3 of

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mri meteorology research, Inc. 464 w. woodbury rd. altadena, calif.

C u.a m PERFORMANCE REPORT hmA*

c.w. 9mm ft ar. 213 Mt 1901

's FOR: Carolina Power & Light -

SENS0R:

1074-22 Wind Sensor S/N 322 -

DATE: 12/7/77 S.O. NO.t 971 637 3576 After Repair i

i NOTE: The following sensor speeds were derived by -

converting voltage outputs to mph from a standard MRI Tachori.eter Card. The typical card has a positive 15mv zero offset output.

Readouts are to the nearest one tenth mph.

True Air . Sensor Speed (NES)* Readout

.4 mph = , Threshold 1.0 = 1. O mph

. 2.0 = 2. 0 l 3.0 = 2. 8 14 . 0 = 4, o 5.0 =

5. 0 10.0 = 10.0 15.0 = 15. 0

, s 20.0 = 20.0 l 25.0 =

' 25.0

30.0 =

! ~

30. O Wind Speed: . 01 oz. in. METEOROLOGY RESEARCH, INC.

Wind Direction: . 37 5 oz. in.

r g

Quality A uranc  ! chnician ..

0 John L. Fenton Manager, Quality Assurance i

k *True air speeds listed were producart in the .".RI Wind Tunnel whose accuracies are traceable to tha ::.tional Sureau of Standards.

C Calibra:ien Specifications surpass applicsble pcragraphs of NRC 3agulatory Guida 1.23. A

%T.2 A Sehssdeser of Cabe. l a s.

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,= . .

U-5

> Meteorology Flesearch,Inc.

r-Box 637.464 West Woodbury Road Altadena.Cahfornia 91001 .

C.

Telephone (2131791 1901 Telex 675421 A Sucsdary of Conu,Inc.

Lllbl'l f PERFORMANCE REPORT i

FOR:- Carolina Power & Light SENSOR: 1074-22 Wind Sensor S/N 334 DATE: December 6,1973 S.O. NO.t 971 638 5490 After Repair NOTE: Sensor readouts are obtained by converting the pulse per second obtained from a LED chopper assembly attached to the anemometer cup shaft.

~

True Air -

Sensor Speed (NES)* Readout

! .7 mph = Threshold L2 = 1. I cph

2. 0  :

1.9

2. 8 = 2. 9 l =

3. 6 3. 7 l 4. 5  : 4. 5

9. 5 = 9. 5 l 14.5 14. 5 19.8 19. 8 24.8 = 24.8 28.1 28.2 Wind Speed. . 008 oz. in. METEOROLOGY RESEARCH, INC.

l Wind Direction . 30 oz. in.

Knac ran, Quality As chnician John L. Fenton Manager, Quality Assurance

• True air speeds listed vers producert in the MRI 'k*ind Tu: nel whose accuracies are traceabic to the Nr.tional Bureau of Standards.

GCalibration specifications surpass applic231e paragraphs or URC 3egulatory Guide 1.23. O4 Rev. 4/10/78 vr.:

.. -. ~ - - - - - - - - - - - - _ _ _

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ECR: Ca relina lhe r k ',ight s-NSOR: 1074 - 22 S/N 320 D.A i E: Decembe r 7,1979 S.O..Nc: 97163?700S NOT .C: ' : .or. : . :.O t r - . ol c~ A :, .?',y.,.,.e .g I c e - c :- se. . i .): t .- cd '.. o a 1 .D i ' : p.: r

- r s . c+1y .- t '. .a. h e ri t o t' < .  : n .: r.et . r . :p h.9 ft.

s. .--

s ru e c. : .- c,.. . .: a or (N '.8)* ,,

T' . :Mout O. 4  :::ph fi.e d.cid O. 8 mph = 0. S mph

}

1. 8 m. ph

1. 8 mph

2. 6 mph 2. 6 mph

~ #

3. 6 mph -

3. 5 mph

( -

4. O

8. 7 mph mph

=

4.1 S. 7 mph

r.ph

13. 6 mph .

13.6 mph

17. 8 mph = 17. 8 n ph 23.I mph = 22.9 mph 25.1 mph = 25.1 mph W /S Shaft .02 oz - in Quality. ;t e.u rance Technician W /D Shaft . 5 oz - in -

/ .

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J '. , #

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Ja ck Sown r 1s o .

• True air s p eds !!,t, d w e r c }>rc duced i !!c M c* i Wind Tc.. .el s he s e a c cu r a cie s a r e t r a s e a tle t o t).e I atir.,r.al ?u r c a u c,f T , a.r a 3 ,

Calil.rati:n Specificatie=, s arpa e, a p plicatie ;.a r.gra;!.s of ;iRC

]R e g2btory Guid e 1. 2 3. y 7 ,. 3 In/70 wT.

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F ER'?CRM AN C E R:-:FGR T 70R: a rolina Power te Light

.cEN SOR : 1(074 - 22 ,S/N S95 D'. -> L: December 7,1979 S.O. No: 9716397038 Sensor . readcsuis are o. c ta:.nec oy cor. vert.,g the

+

. . w. 2 c:

p21se . :: sec ond cbtained from a LED ch.pper as sembly attached to the anemometer cup shaft.

True Air Speed Sensor -

(N ES)* R eadout O. 5 mph = Threshold O. 9 mph  :- 0. 9 mph 1.8 mph = 1. 9 mph

?. 8 m ph. = 2. 8 mph

3. 8 mph .= 3. 7 mph -

.+

4. 2 mph = 4. 3 mph

9. O mph . = 9. 2 mph 14.1 mph = 14.4 mph 18.2 mph = 18.6 mph mph 23.9 mph 23.3 =

25.3 mph = 26.3 mph I

W/S Shaft .02 oz - in Quality Assurance Technician W/D Shaft .5 oz - in

, g j.;. .,,, f,,.

,: ' Jack Sowa rds

=True air speeds listed were produced in t}e MK1 Wind Tu=:.el whose accuracles are traccatie to the Natio=al Bureau of Standards.

x Calitration Specificatiens sur;aer applicable paragraphs of NRC Regulatory Cuide 1. 23. .

Rev. 10/79 W,1

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a n.r .,r e i n. i.'iS,g;. U,.8 g,3... .

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t IIII rincirsirrilssti)~ rrstaircli, iiir.

• 4Ii4 w. nootlinir. sil.

s alt.iilt na, ralif.

PERFORMANCE REPORT ,,,,,,,g,,,,.

FOR: Carolina Power and Light g%;** -

S ENSOR: 1074-22 Wind Speed S/N 334 TEST DATE: June 25,1980 S. O. N O. : 9716308015 l NOTE: The test speeds are calculated from average wind tunnel fan l

speeds which trace to the National Bureau of Standards l through a continuing series of transfer standard calibrations.

The sensor performance is averaged over the same time period and is expressed both as a frequency and a wind speed calculated =.s a linear extrapolation as suming a tachometer i set with 2500 Hz prosiding a 5. 000 V output representing 100 mph.

Test Speed Sensor Pe rformance Error (mph) (IIz) (mph) (mph)

0. 7 17. 53 0. 7 e 0. O

0. 9 19220 0. 8 -0. I C 1. 9 44.80 1.8 ,

-0.1

2. ~9 69.28 2. 8 -0.1

3. 9 91.20 3. 6 -0.3

4. 9 118.90 4. 8 -0.1

9. 8 ' 243.38 9. 7 -0.1 19.6 498.42 19.6 0. 0 24.2 606.23 24.2 0. 0 28.8 722.92 28.9 0.1 33.8 845.27 33.8 0, 0 This sensor is certified '.o meet NRC requirements as expressed in Regulatory Guide 1. 23 (+0. 5 mph) for speeds up to 34 mph using 2500 Hz as the calibration frequency.

, f 3 -

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7.

Tested By '

y/ -

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3. . . v-/_ _

. Thomas J.dLockhart

{

M.inage r, Quality Assu rance rk pa r tm ent s5

a .

U-9 Meteorology Research. Inc.

~ -

Box 637,464 West Wooccury Road Altadena.Cahtornia 91001; .

Telephone (2131791 1901 Telex 675421 till*l a Subsidiary of Conu. Inc.

.g PERFORMANCE REPORT .

CUSTOMER: Carolina Power & Light Co.

SENSOR: 1074-22 S/N: 354 Before Repair: X After Repair:

NEW:

S. O. #: 9716319155 DATE: M' arch il,1981 NOTE: Sensor readouts are obtained by converting the pulse per second obtained from a LED chopper assembly attached to the anemo-meter cup shaft.

[

True Air Sensor Speed (NBS)* Readout

.7 = 'Thr eshold

- 1. 2 = 1. 0

2. 2 = ~ 2. 0

3. 2 = 3. 0

4. 2 = 4.0

5. 4 = 5. 3 10.8 = 10.7 16.7 = 16. 6 22.3 = 22.2

27. 1 = 27.0 36.7 = 36.8 -

M ET EOR LOGY R ESEARCh, INC.

aJ uality Control Technician

/

/U

~

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Oual' As sur ance, Managen,_ se

• True air speeds listed were produced in the' 1RI Wind Tunnel whose accuracies are traceable to the National Bureau of Standards.

/ Calibration Specifications surpass applicable paragraphs of NRC -

\ Regulatory Guide 1. 23.

0,~%.

_. . I "

M0 Meteorology Research,Inc.

. - - > Box 637. 464 West Woodbury Road

[ 'S Altadena, California 91001 .

Telephone (213) 791 1901 Telex 675421 Ilil'8 A Subsidiaryof conu. Inc.

u-PERFORMANCE REPORT CUSTOMER: Carolina Power And Light Co.

SENSOR: 1074-22 S/N: 322

~

NEk Before Repair After Repair X l S. O. f: 9719910343 DATE: December 11, 1981 NOTE: Sensor readouts are obtained by converting the pulse per second count obtained from a LED chopper assembly attached to the anemometer cup shaft to wind speed using 7.64 feet per revolution (25.34 H:/ mph).

True Air Sensor Speed (NBS)* Readout + Difference (mph) (mph) (mph) em

(') 0.84 1.58 Threshold 0.56 1.21

-0.28

-0.31 2.37 2.23 -0.14 3.37 3.26 -0.11 4.34 4.20 ,

-0.14 5.31 4.99 -0.32 10.11 10.09 -0.02 14.92 14.94 0.02 10.65 10.75 0.10 24.52 24.68 0.16 34.86 35.09 0.23 METE 030 LOGY RESEARCH, INC.

ed M ualit Control Technician '

her 4 Quality Assurance Manager Accuracy of NBS Calibration = 0.1 mph Date December 14, 1981 O) b

• True air speeds listed were produced in the MRI Wind Tunnel whose accuracies are traceable to the National Bureau of Standards.

Calibration Specifications surpass applicable paragraphs of NRC Regulatory Guide 1.23.

0$

j' .~* ' s' __

U-11 s

Meteorology Research,Inc. j Box 637,464 West Woodbury Road j ,

Attacena. California 91001 .'

Telephone (213) 791-1901 Telex 675421 'llll'I ]

^ -

A Subsidiary of Conu. Inc.

L PERFORMANCE REPORT CUSTOMER: Carolina Power and Light Co.

S/N: 629 I SENSOR: 1074-22 Before Repair After Repair X NEW S. O. #: 9716320873 DATE: May 26, 1982 Sensor readouts are obtained by converting the pulse per second NOTE:

count obtained from a LED chopper assembly attached to the anemometer cup shaft to wind speed using 7.64 feet per revolution (25.34Hz/ mph).

True Air Sensor s Readout Difference Speed (N8S)* (Mph)

(mph) (mph) 0.57 Threshold -0.16 0.94 0.78 1.86 -0.14 2.00 -0.14 3.13 2.99 4.00 -0.11 4.11 -0.09 5.12 5.03 10.17 -0.10 10.26 0.11 17.07 17.18 23.10 0.17-22.93 0.19

! 27.84 27.65 0.37 i 35.69 35.32 i

METE 030LOGYRESEARCH,INC.

,f M'M Y . . , _

Qu'ali BintTo'lTechnician

/

Q ality Assuranc M anager Date May 26,1982 Accuracy of NBS Calibration = + 0.lmph

• True air speeds listed were produced in the MRI Wind Tunnel whose accuracies are traceable to the National Bureau of Standards.

4 Calibration Specifications surpass applicable paragraphs of NRC &e

~

i. .

) i )J Meteorology Research,Inc. t.q % ]

Boa 637. 464 West Wooccury Road ~ $ '

Aitadev Cahf 0'nia 91001 .

Teleonone 1213) 791 1901 Tele s 675 421  !. ll35*l 7 b* ~""

A Sucsdrary at Cot'u. Inc.

s PERFORf4ANCE REPORT .

Carolina Power & Light Co. S/N: 650 CUSTOMER:

SEftSOR: 1074-22 BEFORE REPAIR X AFTER REPAIR NEW

[ S. 0. #: 9716321331 i

DATE: October 13, 1982 i

NOTE: Sensor readouts are obtained by converting the pulse per second count obtained from a LED chooper assembly attached to the anemometer cup shaf t to wind speed using 7.74 feet per revolut. ion (25.00 Hz/ mph).

True Air Sensor Speed (NBS)* Readout

• Difference (moh) (moh) (mohl 0.63 Threshcid i 0.99 0.66 -0.33 2.04 1.84 -0.20 3.16 2.98 -0.17

- 4.13 3.96 -0.17 5.15 5.01 -0.14 10.36 10.31 -0.05 17.08 17.11 +0.03 22.86 23.00 0.15 27.50 27.67 0.17 34.45 34.63 0.23 METEOROLOGY RESEARCH, INC.

i Quality Cor, trol Technician

! *i . -: .

a 5 /"  ?.R'(.! '

Ouality Assurance Manager  :-

Accuracy of I'BS Calioration =

• 0.1 mph Date: October 20, 1932

• True air soeecs listed were produced in the MRi 'a nd Tunnel whose accuracies are traceable to the Naticnal Cureau of Stanoards.

Calibration Soecifications suroass applic.1ble paragraphs of NRC Regulatory Guide 1.23.

.0

UNITED STATES OF AMERICA NCCLEAR EBGULATORY COMMISSION REFORE THE ATONIC SAFETY _AND LICB SING BOARD In the Mattrar of )

)

CAROLIMA POWER & LZGET COMPANY Dockah Nos. 50-400 CL AND NORTE CAECLINA EASTERN 50-401 CL afUNICIPAL PON1d AGENCY

)

(Bhaaren Harris Ndelear Power )

Plant, Unita 2 and 2) )

AFFZDAVIT CF EIJ.,IAM T. HOGARTH j County of Wake )

us.

)

Stats of North Carolina )

WILLIAM T, ROGARTE, halag duly sworn according to law, deposes and,says that he is Manager - Environmental Techselogy, Harris Plant of Carolina yower & Light company; that the ansvers to Interrogataries 29-3(c) (v-x) contained in " Applicants 8 Responses to Wella addleresn's camaral Interrogatories and Intezzogatories ,

on Contentions 29 and 378 to Applicants Carolina Power & Light Campany, gt,,g,1. (5-socad $st)" are true and correct to the best of his information,, knowledge and beliefr and khat the sources of his information are officers, ensploynes, agents and contractors of Carolina Power a Light Maapa v .

W &A Willisin T. Regarth l

sworn to and subseribed before me, -

this 17th day of June, 1983. -

] f e .

t [W f' W -

wotary Fuhlity ,

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

,BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,

In the Mattar of )

)

CAROLINA POWER & LIGHT COMPANY ) Docket Non, 50-400 OL AND NOP.TH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

AFFIDAVIT OF DAVID McCARTHY County of Wake )

) ss.

State of North Carolina .)

DAVID McCARTHY, being duly sworn according to law, deposes and says that he is Senior Engineer, Harris Plant Engineering Section of Carolina Power & Light Company; that the answers to Interrogatories 29-1(a) (i)-(iv)r29-1(b)(1)-(iv),.29-14e), (g), (n), (p), (r' (s) and (t) , 29-3 (a)-(h) , (m), (n), (o) (1-iv) , p (v-viii) ,

29-4 (e)-(n) , 29-5 and 29-6 contained in " Applicants' Responses to Wells Eddleman's General Interrogatories and Interrogatories on Contentions 29 and 37B to Applicants Carolina Power & Light Company, et al. (Second Set)" are true and correct to the best of his information, knowledge and belief; and that the sources of his information are officers, employees, agents and contractors of Carolina Power & Light Company.

David McCartry sworn to and subccri. bed before me, this 17th day of June, 1983. l LJMDA STAVES Edo- A 21: nl . _ _ _ yra,,,pngua j

' Notary'Publig g g, g g My commission expires (EdM Jupof,/9B M . m , w smes so m m s, a ss

l .

UNITED STATES OF MERICA

. NUCLEAR REGULATORY CO M ISSION BEFORE T)il AIQMIC SAFETY M0 LICENSING BOAR 0 In the Matter of )

)

CAROLINA POWER & LIG)fT COMPAKt D Docket Nos. 50-400 OL AND HORTH CAROLINA EASTERN j $0-401 OL MUNICIPAL POWER AGENCY (Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

AFFIDAVIT OF B. H. WEBSTER County of Wake State of North Carolina )

i B. H. Webster, being duly sworn, according to law, deposes and says that he is hanager - Radiological & Chemical Support Section of Carolina Power & Light Company; that the answers to Interrogatories l

29-1(a), (v-x), (b), (c), (g), (h), (j), (k), (m), (a), and (q);

29-2(j), (k) and (1); 29-3(1) and (p) (f) - (iv); 29-7(a) - (g), and 378-1(a) and (b) contained in " Applicants' Responses to Wells

• Eddleman's General Interrogatories and Interrogatories on Contentions 29 and 378 to Applicants Carolina Power & Light Company, l et al . (Second Set)" are true and correct to the best . of his infomation, knowledge and belief; and that the sources of his information are officers, employees, agents and contractors of l Carolina Power & Light Company.

l R a.7d &

B. H. Webster

/

Sworn to and subscribed before ..rggden ' -

me this /7 day of g,1983. , , , , , , , , - ' : j. ,,

.'- . .A ed .

Me AJ  !

' r {j , ' gig l i.

i 1 -)

ary Publ1C

~~

I My commission e2Pires 9/28/35. .

h.{

l

- , etteet e

/

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

.BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL AND NORTH' CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2). )

AFFIDAVIT OF G. HOYT WHIPPLE County of Leon ) ,.

's* '

State of Florida )

G. Hoyt Whipple, being duly sworn according to law, deposes and says that he is a consultant to Carolina Power and Light Company in the area of health physics; and that the answers to Interrogatories 37B-3(a)-(e), 37B-3(f), 37B-3(j) and 37B-4(a)-(e) contained in " Applicants' Responses to Wells Eddleman's General Interrogatories and Interrogatories on Contentions,29 and 37B to Applicants Carolina Power and Light Company, et al. (Second Set)"

are true and correct to the best of his information, knowledge and belief.

{

vardndN)c G. Hoyt/ Whipple / /

l Sworn to and subscribed before me, l the 16th day of June, 1983.

da,A s 0,uJL[Ltt tw - Ltca A_. -

Notary Public ILhry Mite, !bte d F?dde ~ ._

My Commission Expires !_I? lI",N.?/#'k?.

l -_ __ _

I s

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE AT0 HIC SAFETY AND LICENSING K0ARD I

In the Matter of )

)

CAROLINA POWER A 1.IGHT COMPANY ) Docket Nos. 50-400 OL AND NORTH CAROLINA P.ASTERR ) 50-401 OL MUNICIPAL POWER AGENCY )

l )

Shesron Harris Nucisar Power )

Plants, Units 1 and 2) )

Alr1P7 DAVIT OF JAMES L. WILLIS i

County of Wake )

) as.

• l State of Horch Carolina )

JAMES L. WILLIS, being duly sworn according to law, deposes and says that he in Plant Manager, Harris Plant of Carolina Power &

Light Company; that the answers to Interrogatories 29-1(h), 29-3(j),

and 29-3(k) contained in " Applicants' Responses to Wells Rddlesan's l

General Interrbgatories and Interrogatories on Contentione 29 and 375 to Applicanta Carolina Power a Light company, et al. (Second Set)" are true and correct to the best of his information, kuoeledge j

and beliefs and that the sources of his information are officers, employees, agents and contractors of Carolina Power & Light Company.

47%fA Y s

).. Willis ,

$ worn to and subscribed before me this 17th day of June, 1983.

W '

l $ 2,h j Notary Public

.aQt .

OSTARy My Cotemission expires (b bruk . _/_ _

1. [/gg(,

/

c.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFOBE THE ATOMIC SAFETI AND LICENSING BOARD In the matter of )

)

CAROLINA POWER & LIGHT C0!?ANY ) Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

_ AFFIDAVIT OF SHERWOOD ZIMMERMAN County of Wake )

) ss.

State of North Carolina )

UEERWOOD R. ZIMMERMAN, being duly sworn according to law, deposes and says that he is Manager - Licensing & Permits, Harris Plant of Carolina Power & Light Company; that the answers to Interrogatories 29-1(f),

l 29-2(a) - (h) and 29-4(a) - (d) contained in " Applicants' Responses to Wells l

Eddleman's General Interrogatories and Interrogatories on Contentions 29 and

! 37B to Applicants Carolina Power, & Light Company, et. al. (Second Set)" are true and correct tor the best of his infor=ation, knowledge and belief; and l that the sources of his infor=ation are officers, employees, a6ents and contractors of Carolina Power & Light Company.

ame==

Sherwood R. an I

Sworn to and subscribed b "mer, this 17th day of June, , .,,,R4j'O'%,

41 NT - ad

'~ Notary [Gblic

\ij

.,  ! 5 >

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